How do we document indirect or induced EB-5 job creation?

It is very complex. The contractors or subcontractors are not the created jobs required by USCIS.

USCIS expects to see the I-9s completed by each employee.

It all starts with meticulous accounting records, as a construction project is usually a web of contracts. Keep records in such detailed manner by showing proper accounting and HR classifications of what are indirect or induced jobs. Usually, the contractors' or subcontractors' payroll records detailing jobs created as part of the project will substantially affect the records. A good grounding in discount cash flow analysis (DCF Analysis) should be part of your financial analysis so as to ascertain how the project is being funded. Advisably, either in-house or by way of outsourcing, employ professionals in accounting/finance, human resources and legal services on your project.

Indirect and induced job creation is usually calculated through economic models that consider the expenditures, business activities and geographic area. Maintaining accurate records of expenditures for construction and operations helps, as would be retaining a third party fund administrator keep track of these important items.

If the jobs are construction based, they must not be temporary - under current EB-5 law, both direct and indirect construction jobs created as a result of a foreign entrepreneur's investment, which last for at least two years, may now count as permanent jobs. If a construction project is not reasonably expected to last for at least two years, then only the indirect and induced jobs can be counted. As for proving that you have created the jobs, it is everything from W-2 forms to tax forms to employment contracts.

You can use standard expenditure input-output models included in most economic reports.

Careful, subcontractors and independent contractors are problematic. They are not considered as created jobs for EB-5 purposes. If you are using indirect job counts then you are under the auspices of a regional center. The regional center would have submitted an economic plan showing the number and type of indirect jobs to be counted. USCIS would have approved it already.