EB-5 Business Plan Service

An EB-5 plan built around evidence

Our EB-5 business plan service brings the commercial narrative and financial model into one reviewable document. We work with investors, regional centers, and their immigration attorneys to explain what the enterprise will do, why customers will buy, how operations will be staffed, and how the funding supports implementation. The starting point is the attorney’s brief and the underlying business evidence, rather than a generic immigration template.

A polished narrative cannot repair contradictory assumptions. If the market section describes a local service business while the forecast assumes national demand, the reader needs an explanation. If hiring begins before the premises can operate, the payroll and launch schedule need reconciliation. Our preparation process focuses on these connections so that a reviewer can follow the reasoning from evidence to operating activity and then to the financial statements.

The financial model deserves particular attention because it connects the plan’s most consequential commercial claims. Revenue, capacity, payroll, working capital, and funding should tell the same story. A CPA’s financial discipline helps identify unsupported growth, missing costs, and unexplained cash gaps. It does not establish immigration eligibility or assure any government decision.

The Matter of Ho framework: what a comprehensive plan contains

Matter of Ho, 22 I&N Dec. 206 (AAO 1998), decided July 31, 1998, describes the detail needed for a credible comprehensive business plan. The discussion on printed page 213 links business detail to reasonable inferences about job creation. Its footnote also recognizes that different businesses require different information. Source: AAO, Matter of Ho, pages 212–213 (checked October 26, 2026).

The verified elements are:

• A description of the business, its products or services, and objectives.
• Market analysis identifying competing businesses, their strengths and weaknesses, competing products and pricing, and the target market or prospective customers.
• Required permits and licences obtained.
• Where applicable, production or manufacturing processes, materials, and supply sources.
• Executed contracts for material supply or product distribution.
• Marketing strategy addressing pricing, advertising, and servicing.
• Organizational structure and personnel experience.
• Staffing requirements, a hiring timetable, and job descriptions for all positions.
• Sales, cost, and income projections with an explanation of their underlying bases.

We organize the budget around the decision’s sales, cost, and income projections; “budget” is our planning label, rather than an additional verbatim item in the decision. A useful plan makes the cost of implementation visible alongside the revenue assumptions. It explains evidence gaps and distinguishes signed commitments from management intentions. Describing a possible supplier as contracted, for example, would obscure a material uncertainty.

“Matter of Ho compliant” should describe a preparation framework, never a certification of an immigration outcome. We prepare the business document against these elements and the attorney’s instructions. Counsel reviews its fit within the petition. Our market research guide explains how to build commercial evidence, while the official decision remains the source for the framework.

Job creation: connect the hiring narrative to the model

USCIS’s Instructions for Form I-526 and Instructions for Form I-526E state a requirement of at least 10 full-time positions for qualifying employees. Their descriptions exclude the investor, the investor’s spouse, and sons or daughters. Sources: USCIS, Instructions for Immigrant Petition by Standalone Investor, job-creation section (checked October 26, 2026) and USCIS, Instructions for Immigrant Petition by Regional Center Investor, page 1 (checked October 26, 2026). Counsel determines how the requirement applies to the particular filing.

Our staffing schedule identifies each position’s operational purpose, hiring milestone, duties, payroll assumptions, and relationship to business activity. Sales staff connect to customer acquisition and account coverage. Production staff connect to output and capacity. Administrative roles connect to purchasing, billing, scheduling, and compliance needs. The schedule should explain why each role is needed at the forecast activity level rather than simply reach a target total.

Consider an illustrative operational example: a service business forecasts appointment growth using available work hours and expected utilization. Its model should show the service capacity supplied by the planned team, the appointments that capacity supports, and the payroll incurred while demand builds. This example is a modeling method, not evidence of qualifying employment or a prediction that jobs will be created.

For regional-center work, distinguish the operating staffing narrative from economic job estimates. Direct jobs relate to the project’s employment activity; indirect and induced effects concern wider supplier and household-spending effects considered in economic analysis. USCIS discusses economically and statistically valid methodologies and indirect-job estimates in its Policy Alert PA-2022-23, EB-5 Reform and Integrity Act of 2022, page 2 (checked October 26, 2026). Counsel and the economist must determine the applicable categories, methodology, and evidence; the plan should not invent multipliers or model outputs.

Indirect-job claims typically require an economic impact analysis. A plan writer is not a substitute for an economist. We coordinate the project description, expenditure categories, revenue assumptions, and source documents with the specialist’s brief, while keeping their analysis and conclusions separately identifiable.

Investment amounts and targeted employment areas

Use USCIS’s current publication and licensed U.S. immigration counsel to confirm the applicable investment amount and targeted employment area (TEA) definitions. The reference is USCIS, About the EB-5 Visa Classification (checked October 26, 2026). Direct access to that page was unavailable during this review, so this guide does not reproduce dollar thresholds or detailed TEA definitions. The USCIS Form I-526E instructions, page 1 (checked October 26, 2026) directs investors to USCIS for investment-amount information.

For the business model, we request the amount and classification confirmed by counsel, the intended funding structure, and the supporting location evidence. We record the source and date of the instruction in the assumptions register. A property address, broker’s description, or marketing brochure should not be treated as a legal determination by the plan preparer.

The operating budget is a separate commercial exercise. The costs of equipment, premises, staffing, and working capital should be built from the business’s needs and evidence. They should not be reverse engineered from a headline investment threshold. If the funding available and the operating requirement differ, the model should expose the gap and management should explain its proposed funding response for counsel’s review.

Financial model anatomy: five connected schedules

Capital structure and use of proceeds

Identify the entities, ownership assumptions, funding sources, and intended uses using the documents supplied by the client and counsel. Separate contributed capital, proposed borrowing, and other funding in the model. Map uses to equipment, fit-out, launch expenses, inventory, and operating reserves as relevant. Include the expected timing of funding and expenditure so that an apparently balanced total does not hide a cash shortfall during implementation.

A use-of-proceeds schedule should reconcile with the balance sheet and cash-flow forecast. Equipment purchases should connect to fixed assets and the depreciation policy. Inventory purchases should connect to inventory balances and cost of sales. Working capital should reflect customer collections and supplier payments. These reconciliations make the model easier to challenge and revise without losing its internal consistency.

Revenue built by driver

Build sales from measurable operating drivers such as units sold, billable hours, transactions, customer numbers, capacity utilization, and pricing. Identify the evidence behind each driver and separate management estimates from observed results. Account for the difference between an enquiry, a signed order, an invoice, and a cash receipt. The revenue model should explain both demand and the enterprise’s ability to deliver.

Use local market research and business-specific documents before adopting broad industry averages. Our Canadian business-plan benchmarks study provides planning context, but Canadian observations do not establish U.S. market demand or EB-5 eligibility. An assumption should be relevant to the enterprise’s actual geography, service mix, customer segment, and operating model.

Staffing mapped to operations

Connect the staffing table to the organizational chart, job descriptions, hiring milestones, and forecast payroll. Include compensation assumptions and employer costs supported by appropriate evidence. Distinguish employees from external service providers in the commercial model and refer legal job-counting questions to counsel. A staffing change should flow through capacity, payroll, cash needs, and the narrative together.

Five-year pro-forma statements

Our proposed planning scope includes five-year income statements, cash-flow statements, and balance sheets, supported by linked schedules. Five years is a modeling scope choice; this page does not represent it as a universal USCIS requirement. The level of monthly or annual detail is agreed with counsel and the project team according to the operating cycle and available evidence.

Review profitability and liquidity separately. A business can show accounting profit while running short of cash because customers pay later, inventory builds, or capital expenditure occurs before revenue. The statements should reconcile opening balances, funding, investment, operating cash movements, and closing balances. See our financial modeling service for the broader preparation approach.

Sensitivity and downside case

Test slower sales, delayed opening, higher operating costs, and different collection patterns. Explain which assumptions change and which remain fixed. Recalculate staffing affordability and funding needs rather than leaving payroll or cash balances disconnected from the downside. Any proposed management response should be described as a response to uncertainty, not a promised remedy.

All example financials are illustrative. For an illustrative sensitivity exercise, compare a base sales-volume index of 100 with a downside index of 80 while holding the initial premises cost unchanged. These are modeling indices, not financial results, job counts, investment returns, or a forecast for a real project. Client projections must use the project’s own evidence and clearly identify estimates.

Who we work with: investors, regional centers, and attorneys

We work to the investor’s or regional center’s immigration attorney’s brief. USCIS identifies Form I-526E as the Immigrant Petition by Regional Center Investor and Form I-526 as the Immigrant Petition by Standalone Investor. Sources: USCIS Form I-526E instructions (checked October 26, 2026) and USCIS Form I-526 instructions (checked October 26, 2026). The business plan is one component of the filing materials; it does not replace the petition, legal analysis, or supporting evidence.

At engagement, we agree who supplies the corporate documents, project budget, market evidence, operating assumptions, and specialist reports. We also agree who resolves questions when the commercial narrative and a legal or economic document differ. A controlled review process helps prevent one version of the hiring schedule from appearing in the plan while another appears in the model.

For regional-center projects, coordination may include an economist and securities counsel where applicable. We ask for the relevant project description and agreed assumptions, identify inconsistencies, and maintain a clear revision trail. We do not offer securities, legal, or investment advice. The professional responsible for each specialist conclusion remains responsible for reviewing it.

Process and Atul Jagga’s credentials

Founder Atul Jagga is a CPA (Ontario), has a corporate-finance background, and is an RCIC-IRB, licence R711106. These are factual professional credentials. The RCIC-IRB licence is Canadian and does not authorize U.S. legal practice. Read the about and credentials page for the firm’s background and discuss the precise preparation scope before engagement.

1. Scope with counsel. Confirm the business, entities, document purpose, available evidence, and specialist responsibilities. Identify missing inputs before presenting a forecast as complete.
2. Build an evidence register. Record source documents, dates, assumptions, outstanding questions, and the owner of each response. Separate current operating facts from plans and estimates.
3. Develop the narrative and model together. Connect market demand, pricing, operating capacity, staffing, capital needs, and cash flow. Reconcile totals and explain uncertainty.
4. Review with the project team. Obtain factual corrections from management and scope-specific comments from counsel and the economist. Update linked schedules when assumptions change.
5. Finalize a consistent document set. Deliver the agreed plan and financial schedules with a clear version date and assumptions record. Counsel determines filing suitability.

To begin, supply a project summary, ownership information, available historical accounts, capital budget, staffing outline, and your attorney’s brief. We confirm the deliverables after reviewing the materials. Use the project brief or contact page to discuss the business-planning scope. The business plan generator can help organize initial commercial ideas; specialist review is still needed for this engagement.

Professional scope: business planning and financial models

EB-5 business plan service FAQs

What makes an EB-5 business plan “Matter of Ho compliant”?

It means preparing a credible, detailed plan addressing the framework in AAO, Matter of Ho, page 213 (checked October 26, 2026): business and products or services; market, competitors, and target customers; permits; applicable production and supply arrangements; contracts; marketing; organization and personnel experience; staffing, hiring timetable, and job descriptions; and supported sales, cost, and income projections. The phrase does not certify a petition outcome.

How are the 10 jobs shown in the plan?

The USCIS Form I-526 instructions, job-creation section (checked October 26, 2026) and USCIS Form I-526E instructions, page 1 (checked October 26, 2026) identify at least 10 full-time positions for qualifying employees. We map proposed positions to duties, hiring milestones, operating capacity, and payroll. Existing employment evidence and proposed hiring are kept distinct. Counsel reviews which positions qualify and how the evidence supports the requirement.

Do I need an economist as well as a plan writer?

Indirect-job claims typically require an economic impact analysis; a plan writer is not a substitute. USCIS Policy Alert PA-2022-23, page 2 (checked October 26, 2026) discusses economic methodologies and indirect-job estimates in the regional-center context. Ask counsel to define the economist’s scope. We coordinate commercial inputs without inventing economic-model outputs.

How long should the financial projections run?

Our proposed scope is a five-year model with supporting assumptions and statements. This is a preparation choice, not a claim that USCIS universally requires five years. Counsel should confirm the appropriate horizon and the hiring schedule needed for the filing. Choose reporting detail that makes implementation, working capital, and sensitivity assumptions understandable.

Can an existing business use an EB-5 plan?

An operating business is not automatically excluded simply because it already trades, but acquisition alone does not establish eligibility. The USCIS Form I-526 instructions, page 1 (checked October 26, 2026) describes enterprise formation and specified restructuring or expansion routes; its job-creation section separately discusses troubled businesses. Counsel must assess the transaction and applicable requirements. We distinguish historical operations, existing staffing, and proposed changes in the plan and model.

Related business-planning resources

Return to the immigration business plans hub for the firm’s wider immigration planning services. For commercial preparation, explore business plan writing services and the financial forecasting guide.