The funds must meet the applicable lawful-source, path and qualifying-investment requirements. An inheritance can be a relevant source, but the description alone does not establish the record. Document the entitlement, distribution and funds actually available and contributed, along with any additional evidence required for the case. The enterprise also must create at least ten full-time jobs for qualifying U.S. workers, and the investor must engage in management or policy formulation.
Identify what the estate documents prove
Distinguish an expected beneficiary share from an authorized distribution and a completed transfer. Explain the estate or intermediary accounts accurately. The project’s qualifying investment and job requirements still need independent assessment even when the inheritance history is fully documented.
Start with two separate checklists: the investor's lawful source and path, and the enterprise's capital, job and participation requirements. The first review should identify the document that settles each step, such as a sale agreement, tax return, inheritance record, loan security document or project report. Sequence source verification before an irrevocable transfer where possible.
Hypothetical example: A Canadian orchestra conductor plans to use proceeds from a long-held apartment and a loan secured by another property for an EB-5 contribution. The review must trace both sources and confirm the loan's collateral and repayment terms, while separately assessing the selected project's job evidence. The error is assuming a high net worth removes the need to explain how the particular dollars were obtained.
Maintain a source document index that begins before the funds enter the investor's final account. The first review should identify whether a sale, loan, gift, earnings or inheritance requires additional records from another person or institution. If a link cannot be proved, resolve it before treating the capital as filing-ready.