Short answer: US EB-5 is not only about the investment amount; each dollar needs a lawful source and a complete path from origin to the project account. Common RFEs include income too low to support the capital, parental gifts without tax and transfer chains, corporate dividends without resolutions or books, property sales missing tax and transfer papers, and multi-leg FX or third-party accounts that break the trail. Complete a funds timeline before locking a project and wire.
High-frequency issue types
| Type | Typical gap |
|---|---|
| Salary / business income | Tax returns vs bank credits mismatch |
| Gifts | Donor lacks capacity; missing gift deed and tax treatment |
| Property / share sales | Missing contracts, tax clearance, transfer and credits |
| Corporate dividends | Missing resolutions, audits or ledgers |
| Wire path | Third-party payments, cash piles, unexplained conversion |
Preparation order
- List total investment and each contributor;
- Map documents to each tranche;
- Draw the bank path;
- Have immigration counsel issue a gap list;
- Then subscribe and wire.
Wiring first and documenting later is high risk.
Link to backlog and project choice
Source files often take longer than selecting a project. Mainland China-born applicants also watch visa availability, but a weak source blocks the petition regardless of backlog position.
Global Immigrate note
Complex groups, crypto cash-outs or old cash need a provability review before filing. Marital property and multi-generation gifts must follow local law. Keep original scans aligned with translations.
Information current as of October 2026.
This article is general information, not legal or tax advice. See US EB-5.