Not on its own. EB-5 counts capital invested in a new commercial enterprise that creates at least ten qualifying full-time jobs, at US$1,050,000 or US$800,000 for a qualifying targeted employment area or infrastructure investment as of 7 September 2026. A residence held for personal use creates no qualifying employment and supports no petition.
Test the enterprise, not the address
If real estate is genuinely part of the plan, the question becomes what business will hold and operate it, how capital reaches that business, and which job-creation method the structure permits — direct positions in a standalone case, or the broader methods available through a regional centre. Statutory capital adjustments begin in 2027, so a figure confirmed today should be rechecked before filing. Ask counsel to state, in writing, which requirement each document is meant to satisfy.
There is a further reason to keep the two separate that is about evidence rather than eligibility. The source-of-funds record has to trace the invested capital from a lawful origin, through the accounts it passed, into the enterprise, and a large property payment made from the same accounts in the same period adds a branch to that trail which somebody then has to explain. Buying the home from a clearly different pool of money, or in a different period, removes that work entirely.
Where it is too late for either, the schedule of debits described above is what makes the record readable.