The actual funds and their use must be accounted for. Money spent on separate charges is not automatically qualifying investment capital.
Keep the intended contribution sufficient
Identify government, professional and project charges outside the capital analysis. If the gifts fund more than the investment, document that allocation accurately.
Filing fees at more than one stage from the USCIS fee schedule, administration or subscription fees on a pooled investment, legal fees weighted toward the source-of-funds work, and accounting, translation and independent diligence costs. Because the qualifying amounts and the designation rules have been revised before, confirm the figures and the current area designations against the official program materials at the time the investment is actually contemplated rather than relying on a figure quoted elsewhere. An independent read of the economic analysis and budget is a small expense beside the capital at stake, and the sponsor's report was commissioned to support the offering rather than to advise a subscriber. Government filing fees themselves follow the standard EB-5 petition and adjustment or consular processing structure under the current USCIS fee schedule, and those fees are the same regardless of which capital amount applies. A borrowing investor adds interest, arrangement fees, appraisal costs and legal fees for the security documents, and pays interest throughout a period in which the capital must remain invested and cannot be withdrawn to service it.