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SAINTE-CATHERINE · EB-5 FIELD GUIDE

Does an invoice total prove the expenditure occurred for EB-5 job evidence?

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THE DIRECT ANSWER

Do not assume that it does. Identify the actual transaction stage and the evidence required by the applicable methodology and filing stage.

Read the basis of the number

An invoice, purchase order and payment record show different things. Explain whether a figure is projected, billed or paid rather than describing all scheduled spending as completed economic activity. Three stages hide behind a single number, and naming the stage is what makes the number usable: committed, billed, or paid.

The record that settles which one applies is the project's accounting detail rather than its summary schedule, so ask for the supporting ledger entry and the payment reference for any figure the case relies on. Where a regional-center analysis is involved, ask a further question: which inputs does the methodology actually take, and at what point in the case are they assessed. Some analyses accept projected expenditure at the petition stage and test outcomes later, so a projection is not automatically a defect.

What is a defect is presenting a projection in language implying completion. Describe forecasts as forecasts, describe payments as payments, and keep the distinction in the same words throughout the file so a reader is never invited to assume the stronger reading. A number that changes meaning between documents is the one that will be questioned.