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Money and structure

Sources and uses

Also called sources and uses table, budget table, uses of funds.

The table in an EB-5 business plan or offering that lists every source of money for a project against every category it will be spent on, with the two columns totalling the same figure.

What it decides

The uses column supplies the expenditure figures an economist feeds into the job model, so without it a reader cannot test the ten jobs per investor the project claims. The sources column shows how much of the project is EB-5 money and how much is senior debt or sponsor equity. It also exposes the fee load: where the job-creating entity is separate from the new commercial enterprise, USCIS says that administrative, management, attorneys, finders and syndication fees paid by the new commercial enterprise that erode the capital made available to the job-creating entity do not count toward the minimum required investment, and that those fees must be paid in addition to it. No regulation requires the table today. The statute asks a regional center for a comprehensive business plan and a credible economic analysis with its Form I-956F application, and DHS proposed on 2 July 2026 to write detailed capital requirements including sources and uses of funds into the regulatory definition of a comprehensive business plan.

Governed by 6 USCIS-PM G.2, Made Available, and its footnote 33 citing Matter of Izummi, 22 I&N Dec. 169, 178-79 (Assoc. Comm. 1998) (fees paid by the new commercial enterprise that erode capital made available to a separate job-creating entity do not count toward the minimum and must be in addition to it); Matter of Ho, 22 I&N Dec. 206, 213 (Assoc. Comm. 1998) (contents of a comprehensive business plan); 8 CFR 204.6(j)(4)(i)(B) (comprehensive business plan required; no sources and uses table in the current rule); 8 U.S.C. 1153(b)(5)(F)(i)(I) and (F)(i)(II) (Form I-956F application must include a comprehensive business plan and a credible economic analysis; neither names a sources and uses table); proposed 8 CFR 204.401, definition of "comprehensive business plan," 91 FR 40676, 40691, 40778 (2 July 2026) (https://www.federalregister.gov/documents/2026/07/02/2026-13392/eb-5-reform-and-integrity-act-of-2022-ensuring-the-integrity-of-the-eb-5-program-automatic)

Where this is explained properly

Pages here that go into sources and uses rather than mentioning it.

Related terms

  • Hard costs and soft costsThe split in a project budget between physical construction spending, the hard costs, and the professional, financing and carrying costs around it, the soft costs. Neither phrase is defined in the EB-5 statute or regulations, but the split decides which dollars enter a job creation model and at which multiplier.
  • Capital accountThe ledger a limited partnership or LLC keeps for each investor, recording capital contributed, profit and loss allocated, and anything distributed back out. It is an accounting term, not an immigration one.
  • TrancheA slice of an EB-5 offering that closes separately from the rest, so a project raises its capital in stages rather than in a single closing. The word is market jargon: no statute, regulation or USCIS policy defines it, so a tranche means only what the offering documents make it mean.

Checked against primary sources on . Back to the glossary