Whether commercial property can be counted as part of an EB-5 investment depends on several factors. For all EB-5 investments, the key issue is whether the business will create the necessary number of jobs. For direct investments, job creation is calculated directly, and so the purchase of property may be permissible as long as the business plan demonstrates the connection between the property and the jobs. For regional center investments, jobs are often calculated from expenditures—in such cases, the expenditures cannot include land or property acquisition since real estate transactions do not generate jobs.