Pathway assessments

EB-5 Source of Funds Assessment

The first step in EB-5 source-of-funds review is not collecting documents — it is decomposition: which blocks make up the total, and whether each comes from salary, property, business equity, other investments or loans. This form walks you through that structure in order, with a why-we-ask and how-to-answer note on every section. It covers the RMB source side only, not currency conversion or cross-border transfers. No registration; your draft autosaves in this browser.

What source-of-funds review examines

EB-5 requires proof that the investment capital was lawfully obtained and that it traveled continuously from the original source to the investment. Review is not a single balance statement but an evidence chain per block: salary against income and tax records, property against the full buy-to-sell chain, business proceeds against operations and distributions, loans against the contract, collateral and repayment obligation. Only after decomposition can you see which blocks are well-evidenced and which have gaps.

How this form works

  • No registration. Your draft autosaves in this browser only and is not uploaded until you choose to submit.
  • Every field is optional while you work — record the facts you remember and refine later.
  • Each section explains why the item is asked and how to answer it. Read the note first if a field is unclear.
  • You can print or save a PDF copy for yourself at any time.
  • Submit only when you want our review: a name plus one contact method (email or phone) is all we need.

“EB-5 for Chinese Families: Source of Funds and Path of Funds Are Two Separate Proofs” explains the difference and the documentation gaps Chinese families commonly face.

Read the in-depth article first
Draft autosaves in this browser

Basic information

Why this is askedA funds plan is organized per family, so first confirm who the applicant is and in whose name the funds mainly sit. Details come in the later sections.

How to answerWrite your name as it appears in your passport. Contact details are used only for our reply and are never displayed publicly.

Break it down first

Step one: the total amount and its breakdown

The core EB-5 source-of-funds question is where each part of the investment capital was lawfully obtained. A family's capital is rarely from a single source — it is usually assembled from salary savings, real property, business owner equity (dividends or equity transfer), other investment gains, or loans. This form does one thing: break the total into its source blocks and record how each block would be evidenced.

Why this is askedEach source type follows a completely different evidentiary logic. A bank loan is judged on the loan contract, collateral and repayment obligation; salary on years of income and tax records; property on title and the transaction chain; business proceeds on operations, financials and taxes. Mixed together, nothing can be explained. So the first step is decomposition: the total, which blocks make it up, and roughly how much each contributes.

How to answerRough RMB figures are fine (e.g. "about ¥6m") — precision to the yuan is not needed. Mark estimates as estimates. This form covers the RMB source of funds only; it does not address, and should not be used to discuss, currency conversion or cross-border transfer arrangements.

Important disclaimer: this form organizes only the RMB-source composition of your funds. It is not immigration, investment, tax or foreign-exchange advice, and it does not address currency conversion or cross-border transfers, which are governed by the foreign-exchange, banking and anti-money-laundering rules of China and other relevant jurisdictions. Any actual structure must be reviewed by a licensed U.S. immigration attorney and, where needed, tax and foreign-exchange professionals. State facts accurately; do not describe any arrangement intended to circumvent regulation.

Source breakdown (one row per source block)

Why this is askedThe heart of this form. Each source block carries its own evidence chain; once separated, you can see what each block needs and where the gaps are.

How to answerOne block per row, e.g. "Salary savings / about ¥1.5m / tax paid"; "Bank loan / about ¥3m / secured on property"; "Property sale / about ¥1.5m / sold 2023". Percentages need not be exact — the structure is what matters.

Step two: salary and compensation savings (if applicable)

If part of the total comes from salary, bonuses or service income, record how it accumulated here.

Why this is askedSalary is judged on lawful receipt and tax paid: the employment relationship, payment records and individual income tax records should align — usually the cleanest block. Reviewers ask whether the accumulation is genuine and proportionate to income: ¥6m saved over ten years reads naturally; the same figure appearing over two years calls for explanation.

How to answerLeave the section empty if no salary block exists. Otherwise list employers, years and approximate annual income; separate rows for separate jobs. Ranges are acceptable where exact figures are unknown.

Employment history that produced these savings

Why this is askedChecks the accumulated amount against income level, and identifies the source of tax records.

How to answerOne row per employment: employer, role, years, approximate annual income.

Does this income have corresponding individual income tax records?

Step three: property sales (if applicable)

If part of the funds comes from selling real estate, record the full buy-to-sell chain of each property here.

Why this is askedProperty as a source answers money at two points in time: where the original purchase money came from, and how the sale proceeds arrived. Title records, sale contracts, tax receipts and the receiving account together form the chain. Early cash purchases and missing paperwork are common — record the situation honestly and let the attorney assess how to bridge gaps; never recreate documents after the fact.

How to answerOne entry per property: city, purchase year and approximate price, sale year and price, and which account received the proceeds. Multiple properties on separate rows.

Properties used to raise funds (one row each)

Why this is askedEach property is an independent buy-hold-sell evidence chain; separating them keeps the chains unmixed.

How to answerCity, purchase year and price, sale year and price, account that received proceeds. Note whether documents are complete.

Where did the money to originally buy these properties come from?

For example earlier salary savings, business income or family support — a rough account is fine. This is the next layer reviewers ask about; better recorded now than answered later.

Step four: business owner equity — dividends or equity transfer (if applicable)

If funds come from a company you hold — dividends, profit distributions or an equity transfer — record the company and how the funds were obtained here.

Why this is askedBusiness sources are judged on genuine operations plus lawful distribution: operating records, financial statements, taxes, distribution resolutions or equity transfer agreements, tax on the distribution, and the record of funds entering your personal account. The most common problems are off-book distributions or mixed personal/company accounts — state such facts honestly; the attorney must know early to assess how to handle them, and concealment is far more damaging than the fact itself.

How to answerNote the company, your shareholding and role, how the funds were obtained (dividend or equity transfer), and the approximate amount and year. Separate rows for separate events.

Funds from the business (one row per event)

Why this is askedDividends and equity transfers have different chains: dividends rest on resolutions and profit, transfers on the agreement and consideration.

How to answerCompany, your holding, how obtained, year and approximate amount, and the tax record for it.

Does the company have proper financial statements and tax records supporting the distribution?

Step five: loans (if applicable)

If part of the capital is a bank loan or other borrowing, record the lender, collateral and repayment obligation here.

Why this is askedA loan as a source is judged on three things: genuine disbursement (contract and funding records), adequate collateral (what it is and who owns it), and a real repayment obligation (who repays and from what). A bank loan secured on property in your own name is a common, explainable structure. But what secures the loan and who owes repayment affects the legal analysis — especially any relationship between the collateral and the investment project. Do not apply templates; an attorney must review the specific facts.

How to answerOne row per loan: lender (bank or individual), amount, collateral and its ownership, repayment arrangement. For loans not yet taken, describe the planned arrangement.

Loan details (one row per loan)

Why this is askedEach loan must independently explain its source (disbursement record), collateral and repayment.

How to answerLender, amount, what the collateral is and in whose name, who repays and over what term.

Source and status of the collateral

For example when the mortgaged property was bought and whether a mortgage remains outstanding. The collateral's own source is also examined — record it now.

Step six: other sources — gifts, investment gains and other after-tax income (if applicable)

Anything outside salary, property, business proceeds and loans goes here — most commonly family gifts and other investment gains.

Why this is askedA gift does not reduce the proof burden; it shifts it to the donor: the donor's own source of funds, the fact of the gift (a gift agreement), and how the money reached your account. Gains from stocks or funds are evidenced by holding and transaction records. Every source shares the same floor: after-tax, lawful, traceable. One unexplained block weakens the whole chain.

How to answerOne paragraph per source type: what it is, who gave it (for gifts), approximate amount and year, and what records exist.

Family gifts (if applicable): donor, relationship, approximate amount, and the donor's own source of funds in outline

The donor's source must also be explainable; record what you know in outline.

Other investment gains (if applicable): stocks, funds, wealth-management products — how they were held and liquidated, and where the records sit

An outline is fine; what matters is whether transaction records exist and at which institution.

Other after-tax income (if applicable): source, year, amount and supporting records

Step seven: how the funds are currently held (RMB accounts only)

Once sources are clear, it must also be possible to show where the money currently sits and in what form. This section records only the current position in domestic RMB accounts.

Why this is askedAdjudication requires the funds to be continuously traceable from the original source to the investment. Which accounts hold the money, how many times it has moved, and whether each movement is documented decide whether the "path" evidence chain is complete. Normal, genuine consolidation between accounts is fine; what must be avoided is arranging flows to manufacture a paper trail — that creates an authenticity problem far worse than any gap.

How to answerDescribe the general picture: across how many banks the funds sit, whether in your own name or family members' names, and whether large transfers between these accounts occurred in recent years. No account numbers needed.

To restate: this form does not address currency conversion or cross-border transfers in any way. Cross-border steps are governed by the foreign-exchange, banking and anti-money-laundering rules of China and other relevant jurisdictions and can only be discussed with the appropriate professionals during an actual engagement.

How the funds are currently held (in your name or family members', across roughly how many banks)

Structure only, no account numbers — e.g. "two banks in my own name, one account in my spouse's name".

Have there been large transfers between these accounts in recent years?

Anything else and timing

Anything else that may help

Information outside the categories above, including the block you feel least sure about.

Timing: when you hope to complete the investment, and any hard deadlines

For example a project subscription deadline or a child's age. We use this to sequence evidence work; it is not a processing-time commitment.

Visa and family background

Why this is askedPrior visa applications and refusals affect how the consular or adjustment stage is handled, and that needs to be known at the outset rather than discovered before an interview. Relatives in the U.S. can indicate parallel options or a family timeline that must be planned alongside your case.

How to answerApproximate dates are fine. A past refusal does not by itself end a case, but report it accurately — an undisclosed record causes far more trouble than the record itself.

Have you applied for immigrant, student or visitor visas before?
Have you ever been refused an immigrant, student or visitor visa?

Spouse and children, if any

Include birth years. If a child is approaching 21, the family timeline needs separate planning.

Do you or your spouse have relatives in the United States? Note the relationship and where they live.

Submit to TIHU for review

We will prepare an initial review based on the facts you entered and reply through the contact details you leave. Please double-check your name and contact information before submitting.

Draft autosaves in this browser

Looking at the other pathway too?

EB-5 direct investment assessment
Explore pathwaysBook a consultation