Do not assume private training expenditure creates a credit against the published programme gift.
Build the budget from distinct obligations
Processing is US$15,000 nonrefundable per person and the corporate gift is US$2 million per sponsored employee when instructed after successful vetting. Published corporate maintenance and transfer terms also require separate review; ordinary hiring costs should not be presented as satisfying them.
Construct the budget in chronological, nonoverlapping categories. First comes the online application with a US$15,000 nonrefundable DHS processing fee for each person. Next, USCIS issues an I-140G filing prompt. After successful vetting, current terms request a US$2 million gift for a corporate-sponsored principal; the corresponding individual-principal gift is US$1 million, and eligible included relatives have separate published amounts. Training, recruitment, salary, relocation, maintenance, and transfer expenses should each retain their real purpose. None creates a credit against the government gift, which is not an EB-5 investment and should never be described as capital at risk. EB-1 or EB-2 classification, admissibility, and visa availability remain separate conditions rather than purchased benefits. Re-verify the portal and official instructions before money moves. The typical accounting error is netting private employee development against a government obligation.
Hypothetical example: A mineral-testing company from Sainte-Rose-du-Nord pays for an analytical chemist’s specialized training before considering corporate sponsorship. Its forecast records that course as workforce development and leaves the published principal gift untouched. Finance also waits for post-vetting instructions instead of sending the difference early.