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Programme guides · US EB-5 Investor Immigration

EB-5 Source of Funds 2026: Common RFE Causes and Preparation Order

Written by Global Immigrate consultants · Reviewed by Oscar Yip, Founder & Managing Director

Summary

EB-5 requires proof of lawful source and a complete path of funds to the project. Common RFEs stem from income mismatches, broken gift chains, thin corporate dividend files or unclear wires. Build a funds timeline before choosing a project.

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.

Information current as of October 2026.

What are 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

What is the right preparation order?

  1. List total investment and each contributor;
  2. Map documents to each tranche;
  3. Draw the bank path;
  4. Have counsel issue a gap list;
  5. Then subscribe and wire.

Wiring first and documenting later is high risk. See US EB-5.

Can parental funds be a lawful source?

Yes, if the parents’ capacity, gift process and tax/FX compliance are proven.

Can a company invest directly?

EB-5 investors are generally individuals; corporate profits must be lawfully distributed to the person first.

Global Immigrate field notes

Complex groups, crypto cash-outs or old cash need a provability review before filing. Marital property and multi-generation gifts must follow local law. Applications are handled by Global Immigrate’s in-house team; regional center charges should be referred to as management fees.

If you are preparing EB-5 alongside talent paths, use programme matching or contact advisors.

This article is general information, not legal or tax advice.

FAQ

Can parental funds be a lawful source?

Yes, if the parents’ capacity, gift process and tax/FX compliance are proven.

Can a company invest directly?

EB-5 investors are generally individuals; corporate profits must be lawfully distributed to the person first.

Are large cash deposits a problem?

Large cash needs a clear origin story or RFE risk rises.

Can source issues cause permanent refusal?

It depends on the facts; serious misrepresentation has severe consequences—prepare accurately.

Should I pick a project before source documents?

Complete the funds timeline and gap list first, then lock a project.

Sources

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