Examine the actual use and treatment of each payment rather than infer qualifying capital from its label.
Separate service administration and contributed capital
General capital is US$1,050,000 or US$800,000 for qualifying TEA or infrastructure investment, with statutory adjustment from January 1, 2027 and actual filing-date review. Do not automatically count every charge or exclude every amount without reviewing the underlying transaction.
An administration or management charge is a service fee under the operating documents, not automatically capital placed at risk in the new commercial enterprise; the two must be traced and classified separately. Read the subscription and operating agreement to see what each payment purchases, whether it is refundable, and whether it appears in the capital account or a separate expense ledger. The general EB-5 threshold is US$1,050,000, reduced to US$800,000 for a qualifying targeted employment area or infrastructure project, subject to the applicable filing-date rule; meeting that figure still requires documented lawful source and path of funds, creation of ten qualifying full-time positions, and the investor's management or policy participation. A regional-center structure generally uses Form I-526E, while a direct investment uses Form I-526; conditional residence and the later Form I-829 stage follow approval. Treating every invoice as either fully qualifying or fully excluded, without reading what it actually pays for, is the recurring error.
Hypothetical example: A machine-shop owner from Saint-David-de-Falardeau wires his capital contribution together with a separately invoiced project-management fee. He asks the fund administrator to confirm in writing which portion is recorded as at-risk capital before relying on the total for his I-526 filing.