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EB-5 Project and Investor Financial Accounting – Best Practices for Compliance

Sam (00:08):
Hi everyone. This is Sam Silverman. Thank you for joining us today. In today’s webinar, we’re going to talk about EB-5 project and investor financial accounting best practices so that your project remains in compliance.

Sam (00:25):
During the webinar, if you have any questions, please use the chat box on the screen, and we’ll try and cover as many questions as we can at the end of the webinar. But if you have questions at any point, just submit them, and then we’ll try and cover as many as we can at the end. So, quick overview of what we’re going to cover today. So, a little bit about our guest speaker and EB-5. We’ll talk about common project investment structures for EB-5 deals, some financial accounting best practices, what are the, kind of, minimum required annual accounting documents that most projects are going to need, common pitfalls to watch out for. And then we’ll open it up for questions at the end.

Sam (01:16):
So before we jump into the materials, for those of you looking to set up your own EB-5 project, most projects, as you probably know, are done in targeted employment areas, or TEA areas, where the minimum investment is only $900,000, instead of $1.8 million. We recently launched a new TEA map. It will instantly tell you, using all the available potential qualification methodologies, if your site qualifies as a TEA. And if it does, then it’ll produce a targeted employment area qualification report for free as well. So, if you’re looking to see if your project does work as a TEA, check out our map—it’s completely free and very helpful. For more information on other topics and EB-5 marketing, job creation, structuring a regional center, ownership, creation, operation, all those topics and more, and a large FAQ, refer to our EB-5 guidebook. You can download it for free at, or you can get a hard copy on Amazon as well. All right. So, as I mentioned earlier at the beginning, I’m Sam Silverman, joined here by my partner, Mike Schoenfeld, and I’ll let him quickly jump in and introduce himself.

Mike (02:38):
Hi everyone. Thanks for taking the time to join us today. So, as Sam mentioned, we founded EB5AN many years ago. You can see my background on here. Sam and I worked at the Boston Consulting Group together before we started this company, and at this point, we have 14 regional centers approved and they cover over 20 states, and we’re one of the leading EB-5 consulting firms in the industry.

Sam (03:07):
Great. Thanks. Thanks, Mike. So, for additional background on EB5AN, we’re a national regional center operator and fund manager, so we own and operate all these regional centers ourselves. And then, we also manage select EB-5 projects as well. So, some high numbers, high-level numbers on the right side here, and then, in terms of our regional center coverage network, uh, this is a map that shows, kind of generally, where we have approved regional centers around the country.

Sam (03:44):
One of the most important things that we’re very proud of is that over 1800 investors across more than 60 countries have invested in projects sponsored by our regional centers. And it’s really important to us that a wide variety of investors from a wide variety of backgrounds have consistently found value in our approach to structuring EB-5 investments under our regional center network.

Sam (04:25):
And today, we have the pleasure of being joined by our guest speaker, Jana, and I can never pronounce the last name correctly. I’m not going to try to do that right now, but Jana has been with us from the beginning. Her team handles all of our tax-compliance reporting, K1s, all of it. So we’re really excited to have her with us, and I’ll let her jump in and introduce herself and share a little bit about her kind of general accounting background and EB-5 specific work that she’s done in the past.

Jana (05:10):
Yeah. Thank you, Sam and Mike, for inviting me to speak. I’m a tax partner with Marcum, LLP. We’re a full-service accounting firm. We prepare audit and tax and advisory services. I mean, I work in the tax department, and I work with companies, closely held companies, businesses, partnerships, with real estate and within the realm of EB-5, we started about 10 years ago, working with investors and immigration attorneys to work on the investor source-of-funds reporting. And that kind of led into us also handling some tax work and accounting work for some of the new projects that are being set up and the investor partnerships and assisting with that compliance from a tax perspective and a consulting perspective, giving guidance on, you know, having everything properly documented and prepared. So, we work on both sides of the business side—the projects and then also the individuals and assisting with their applications for their source of funds.

Sam (06:24):
Great. Great. Thank you, Jana. All right. So, to start out, we’re going to chat a little bit generally about some of the most common EB-5 project investment structures, and then we’ll dive into how the accounting requirements and process is going to vary a little bit across which project structure you decide to utilize for the investment. So, in general, today, the two most common types of EB-5 investment structures are limited liability companies and limited partnerships. Those tend to be the most commonly employed structures. So we’ll spend a minute first talking about LLCs at the top, and then we’ll shift to LPs. So in general, LLCs are a little bit more flexible. You can have a single member, you can have multiple members managing—it gives you an option of having a little bit more flexibility around allocation of income and expenses.

Sam (07:32):
And when your tax is a partnership, it’s a little bit different, and I’ll let Jana jump into that when we get to the next slide. But in general, LLCs are going to give you a little bit more flexibility than partnerships. With that said, most of the partnerships or, historically, most real estate investments, where you’ve got a number of limited partners who are just putting in capital, and you’ve got a manager who’s just making the decisions and is administering the investment itself, historically, more deals were done using LPs. The shift to LLCs has been kind of more recent. That said, like, most EB-5 projects today, I’d say probably 70, 80%, from the ones that we’ve sponsored, still utilize the LP structure. It’s just a little bit, I would say, more formal. And it’s just, historically, when you’re talking about foreign investment into the United States, it’s a little bit more common to have that investment be structured with an LP versus an LLC.

And what we’ve seen in EB-5 over the past decade is the majority of EB-5 deals are structured with those LPs. That’s just the historical norm. And I’d say that the market is more accepting of that. LLCs we’ve seen on smaller deals, but the typical EB-5 structure is definitely in the limited partnership style.

Sam (09:12):
Yep. And there are some more expenses, too, when you’re dealing with LPs—there’s some more annual filing fees, and the entity’s a little bit more expensive to create. So, it is a little bit more expensive, but when you’re dealing with larger projects, it’s a very tiny percentage. So, you know, it really only matters a little bit when you’re dealing with a smaller project where you might not have as much, you know, total capital going into the deal. So, now we’re gonna shift gears and kind of quickly walk through what a sample deal structure looks like using a limited partnership, right? So, first, the partnership is here in the center here in blue. So, whatever the partnership is, typically the partnership is the new commercial enterprise, or the NCE, and the deal that partnership is going to have. Limited partners are up at the top center here.

Sam (10:06):
Each investor is a limited partner. Assuming they come into the investment, you know, before the rule change, it would have been $500,000. Now, this is $900,000—plus some subscription fee is pretty common. Then, the partnership is going to be sponsored by a regional center. So, one of our 14 regional centers would execute an affiliation or sponsorship agreement here to provide the indirect or induced job creation benefit to the EB-5 investors so they could get credit for construction costs, job creation, and revenue creation as well, instead of W2 jobs only being able to count toward the required 10 jobs per investor. Now this partnership is going to be managed by a general partner, so a separate entity, typically an LLC, which will be the manager or managing member of the partnership. Typically you’d call it the general partner, right? So, that entity comes in and controls the partnership, makes all the decisions.

Sam (11:13):
Then, in a typical loan style structure, the partnership would make a loan here of some amount of capital into an upstream borrowing company. And, in exchange, that company would issue an equity pledge back to the partnership. And then, that upstream borrower would contribute those funds into the development company. And the reason the money is loaned to this intermediary upstream entity is because most senior lenders here—this would be like a Wells Fargo regional bank that is making a traditional senior loan. That’s going to be by a first deed of trust or a mortgage on the property. These types of institutional, large, maybe publicly traded lenders, they don’t want to have any other loan that’s going directly to the development company, just to make sure that their loan is totally perfected and there’s no chance it’s going to be subordinated, or if there’s going to be any potential claim that it would be not senior and not secured, they don’t want to have another loan happening at this company.

And so, that’s why you’ll have an intermediary here. We call it an upstream borrower that will take the capital and then contribute it. And so, from the bank’s perspective, the capital coming in here is not additional debt, right? And then, the developer, the sponsor of the project, will typically own the development company and the upstream borrower. And they’ll also, in most cases, be contributing some amount of equity into the project. And so, the project gets built with equity, some EB-5 proceeds, and then some third-party, more traditional senior construction financing. So that’s kind of typically how the structure is done using the partnership. It’s slightly different using the LLC. But, you know, again, generally, this is typically how you would be looking at structuring using either one. Mike, any comments on that?

Mike (13:25):
No, I’d say that this is going to be the standard structure for the LP. It does not change that much if you’re using an LLC, other than the general partner would collapse and be a managing member in that partnership name box that we have for the LP now. But I would say that this is the standard EB-5 structure that we’ve seen. It can get much more complicated if there’s multiple equity partners coming into it. And a little bit of it depends on the senior lender. But I think that was a great overview, Sam.

Sam (13:58):
Okay. So, we’re now going to jump a little bit and dig into some of the accounting details. So, I’ll turn it over to Jana and kind of let her walk through, you know, what are some of the major accounting requirements that partnerships and LLCs are going to have to meet, and then talk a little bit about the investor side of these transactions for what the investor is going to want to get from the partnership or LLC and how that’s going to fit into the investor’s, kind of, overall tax reporting that they’re going to have to do on a personal level.

Jana (14:36):
Okay, perfect. So, looking at the structure—which, I agree, this is a traditional structure for these EB-5 projects—it does look like there’s a lot of different movement around. I think the best practice—there’s a couple of them as far as when you set up the structure or you hire someone to set up the structure—that you understand it, and you understand the way the money is flowing or should be flowing, and you have your development project and your company. And then, now, you have all of these additional, several entities, and you have to honor the structure and honor them as separate legal entities. So, some of the… you have to set up bank accounts, you need to set up accounting software, QuickBooks, or, you know, there’s not a lot of activity that’s going to be going through these entities; however, it’s important for your accounting and for your tax preparation, but also for EB-5 to properly have the funds from EB-5 flow according to the structure that’s in place.

Jana (15:48):
And sometimes, it’s just… here’s the structure, but maybe understanding it and then getting, quickly, you know… at the beginning, setting up the appropriate accounting for that and support so that you are in compliance and you have all of the recordkeeping very transparent. Some of the other items, another item is just recording any bridge financing. Bridge financing comes if you are doing a developmental project and the funds are needed to start that project earlier than the EB-5 funds are available. You don’t have as many investors, or the money is in escrow—for whatever reason, the funds are needed and they may not be available. So, sometimes, the sponsor will need to put money in as a loan. And then, at that point, when the EB-5 funds are available, they’ll be repaid back their funds. It’s important that that is allowed for EB-5.

Jana (16:47):
However, it does need to be documented. And sometimes, when things are very closely held, the money doesn’t always go into the right entity. And it’s very important with EB-5 to properly document the loan, have the funds run in the appropriate entity, in the appropriate bank account. And that’s something that is one of the first conversations I have, is just making sure that everyone is aware of what accounts are there with the business purpose and what each entity is responsible for and what they’re responsible for paying. And that goes for the EB-5 fees as well—paying, you know, for the legal organization, the marketing fees—they must come from non-EB-5 funds. So, this kind of all goes together. So, it’s all part of your accounting and part of your recordkeeping. It’s just another—and like I said before, there’s not a lot of activity that would be going through these entities, but it is important not to commingle everything into one development company because it would just need to get unraveled.

Jana (17:56):
And it’s just not for EB-5 documentation—it’s just not advisable. Another thing, and this is really not with regards to EB-5, it’s accounting and partnership overall, is that having your legal organizational agreements, like having these entities set up properly, having the underlying partnership, LLC, LP, whatever you decide, having those agreements in place so that it is documented. How are the funds going to be allocated to each of the partners? How is the income, how are the losses, when will distributions be made? Will there be a preferred return? Things like that, which, again, going with what Sam was talking about partnerships, LPs, LLCs—there’s a lot of flexibility that can be done with these agreements, but having them in place dictates how you file your tax return and how you operate as a partnership.

Mike (18:55):
And that’s a great point. So when do you think that an EB-5 sponsor should start speaking with you or get their accountants involved? Because we see quite often people wait until they’re filing taxes for the first year before they’re getting other accountants involved, and sometimes there’s issues. So what would you suggest in terms of the process to get this all set up, and how would that work with Marcum?

Jana (19:17):
Well—and you’re right, sometimes it is—it’s when the filing deadline comes up and they’re like, “Wait, I have only these returns. I need to file.” It’s important when they’re first organized to have a conversation and to talk about what needs to be done now, whether they want to keep their internal bookkeeping, accounting, separate with their business bookkeeper, just separate accounting. We can help them set that up, and they can take it from there. And we can look at, you know, follow back up closer to the end of the year. We have a service where we, on a quarterly or monthly basis, pull the bank accounts and update their accounting accordingly. For the most part, sometimes it’s just a matter of getting the 12 months’ worth of activity and booking for the records. It’s also the conversations that need to be also had, because as you’re moving through, “I’m receiving this money, how do I report it? How can I get it? Can I take a check? Can I reimburse myself for any loans that I’ve put into the company?”—having those conversations are very important so that something isn’t just done—not for any malicious reason, it was just an error and not understanding the structure. So, from the beginning, having just a few conversations at the beginning will just make a big difference.

Sam (20:36):
Jana, what about the difference between accrual versus cash and how to deal with that? And what’s most common for EB-5 partnerships?

Jana (20:46):
For the EB-5 partnerships, this is an entity—it’s a partnership that is loaning money. So, the foreign investors are partners, and they’re going to receive a K1 and a filing as a partner in a partnership. There’s also… what we see is cash basis is the most common method for this type of entity. And that puts more of a reflection of “the income is not reported until the income is received.” Some of these agreements—maybe there’s some accruals, and you can accrue the interest or you accrue fees and things like that. That just doesn’t have a really good matching process for the investors. So, we found that just using the cash basis is the easiest and most common.

Sam (21:34):
Got it. Got it. Okay, great. So, now we’re going to shift gears and kind of talk about the nitty gritty. What are the actual documents that are going to need to be filed on the partnership side and then on the investor side?

Jana (21:50):
Sure. So, the annual reporting, it’s the federal and possibly states. For these entities, it would be a partnership. It’s Form 1065. And it’s the same. It’s nothing different because it’s EB-5, but it is a partnership filing. Something to note also is in some states, not all, where the underlying asset that securing the loan is located—some states may require you to also file in that state as well. And that’s just something to be aware of for the investments. So, you have your annual filing. And, like I said, the partnerships will file and provide a K1, it’s called a K1, and it will be provided to all of the partners, and that’s filed every year. There’s also, because they do receive these K1, anyone who is a partner would have possibly some personal filings, depending on their status, depending on are they considered a U.S. resident or U.S. taxpayer because they are in the US for a certain amount of days.

Jana (23:00):
And that just needs to be addressed. So, they may not be aware that they’re going to get this K1, and what do they do with it? There is some foreign reporting—if this is interest, and if it is subject to withholding for some of the foreign partners, then there will be some reporting. And that is on the partnership’s responsibility to withhold the funds needed for the tax and submit those to the IRS. So that’s a requirement, and it’s a matter of just determining your investors, who, because their statuses will be changing for different reasons… it’s knowing what the status of those investors are for U.S. tax purposes.

Sam (23:46):
And let’s spend a quick minute and talk about… you mentioned different states, different requirements. Where do most of these partnerships, general partners, get set up, and why? And how does that impact the filing requirements?

Jana (24:03):
Well, what happens is it may not be necessarily where they’re organized. It may be the underlying asset that they’re secured by, by the mortgage. And that’s really a state-by-state issue. California, just for an example… if you have a mortgage or a loan with a piece of property that’s in California, they’re going to look at this NCE, this partnership and say, “You need to file in California as well.” That’s one of the most common ones that I’ve seen.

Sam (24:37):
But in terms of formation, most of these are formed in Delaware, right?

Jana (24:41):
Correct. Correct. Yes.

Sam (24:44):
Okay. Well, let’s talk a little bit about the requirements. So, when you get to the I-829 stage of the EB-5 visa process, you obviously have to show not only that job creation happened, the 10 jobs, but you also have to show the capital for that investor has remained at risk for the duration of the project, right? So, you know, on the first part, you basically need financials to show how much money you spent on construction, in most cases. So, having the right accounting in place is going to help you do that. And then, secondly, you’ve got to show that the money came in for that investor, and then it remained there, and it’s still there, and it hasn’t been paid back. So, on that second point, what types of documents does the fund need to have to include as part of the I-829 to show that, you know, they got the money when they got it and that, you know, they’ve continued to have it and it hasn’t gone back?

Jana (25:45):
And that’s why, you know, we were talking about the first thing to do is having your accounting in place and use, you know, receiving deposits and making payments out of the appropriate bank accounts for the correct entities. It is important when you have to do this reporting that you do have, you know, support and documentation, not only in a financial, you know… you can have your financial information, but you have the underlying support for that as well. So, you do need to show that that money went into the investment partnership and then show those funds either being accumulated or, as each partner comes in, being moved to the appropriate… as a loan, as a proper loan. And I had mentioned just keeping everything as if it’s a separate legal entity. And sometimes, you know, you do see where, unfortunately, someone wasn’t aware, and they deposited money straight from the investment into the project.

Jana (26:45):
And that just requires, you know… we have to have the documentation, and it’s a little bit of a wrinkle when you’re trying to show the structure. And, you just have to have investor information proof of the deposits coming in, showing the money going into the project. And then, once it’s inside the project, making sure that it’s being used for project expenses—showing the money coming in and then maybe coming back out as a distribution to the owner—that’s not allowed. So, it’s important to have the money coming in and showing that it’s being used inside the project for project expenses. Obviously, that’ll come through on, you know, the support needed for the jobs. And then, obviously, the investment partnership will have its own bank account to reflect any interest payments going out, any repayments going back to the partnership, which there should not be. And things like that, that would all be part of the accounting for the NCE and part of the tax return. It would be very clear if there was a repayment of that loan.

Sam (27:58):
Right, right. Exactly. Got it. Okay, great. We’re going to shift now and talk a little bit about common problems. Like, where do people get tripped up, and how do you, you know, other than talking with, you know, you or another accountant as early as they can, you know… what are just some of the things that people can do to try to minimize having problems that aren’t easily corrected?

Mike (28:28):
Exactly. And I think it would be helpful, too, if you jump in and let us know, sort of, when you see people engaging you and what problems you run into, so we can go through some of these pitfalls. But then, I’m sure you see the same exact problems if you get engaged at the beginning versus the middle versus the end and all of that.

Jana (28:46):
Yes. And I think we’ve kind of talked a lot about this, and in that conversation is the delay in, you know… accounting seems to be a very large one, waiting to set these up until I have to file tax returns. I have the structure, what do I do? And sometimes, you know, we have to step in at that point, kind of trace all the funds, and get that into place. And what happens is it’s not only a delay in the accounting—it’s, like I said, maybe the money didn’t move as well as it should. Maybe some expenses were paid personally, not through the entity, things like that. It just causes stress for both the group. And it’s just, as soon as you can get it in place and get it proper, that’s just the best thing that can be done.

Jana (29:36):
A lot of things that we see is… we’re not, you know… sometimes it’s when, maybe, their investors are asking for support, maybe it’s when the bank is needing some more information. That’s when we’re brought in. And sometimes, it’s already a year down the road, and that’s why getting us in front or having your accounting upfront is so important. And when I see, you know, people, you know, in projects that have had issues, really it’s been around keeping those structures in place and communicating with their investors and providing the financials to their investors, because if they haven’t done the accounting properly, there’s no way that they can provide the proper financials or income numbers that are required under EB-5. And because they have these outside investors, there’s foreign reporting as well. I mean, these partnerships are made up of foreign investors.

Jana (30:41):
When you have foreign investors, you have foreign, you know, some reporting that you need to do every year. You also may have some withholding requirements that you need to do. And all of these are required. Foreign reporting, from a U.S. perspective, is a pretty hot topic. And there’s some pretty big penalties if you don’t file on time. So, these are important to know, and it’s just a matter of staying on top of your investors, as far as their status and making the correct filing so you can avoid any penalties. And sometimes that may happen—you file a tax return, you say you have a foreign investor, then you receive a notice from the IRS saying, “You should have filed these returns,” and that’s where I’ll get a call or something like that. So, I think those are the, you know… I think those are pretty much the hottest ones that I’ve seen, and it’s really about co-mingling funds and making the appropriate repayments to the owner for loans that they’ve made and things like that. And keeping everything very structured, because it’s not just the owner and his business. Now you have foreign investors, and you now have, because of the visa, these applications, then you have, you know, the government looking in on the accounting as well.

Mike (32:06):
So one thing that we’ve seen more often than we think we should is that some smaller projects, they put out their documents, they find two or three investors. They move forward with a deal. They build—let’s say it’s a small hotel or a small apartment building, never really focused on the EB-5 part. The I-526 has got approved. And then, at the I-829 stage, we get a call where they’re looking and they send us the books, and it’s very clear that the money did not flow as intended. So, rather than ever touching the JCE, the money was moved around, things like that. Is this something that Marcum can help with in terms of documenting the flow of funds and why money is fungible and things like that? Or do you typically try and stay away from something retroactive where you’re explaining why somebody maybe made a mistake?

Jana (32:55):
No, we have done that for a couple of projects where it did come out at the end, you know, they needed the support. They did use the money, they had the EB-5 money, they use it appropriately, but it was not properly documented. So, what we’ll do is from an advisory perspective, because it’s really not a tax, would be going through and documenting the flow of the funds and to kind of retroactively, like you said, go through and document how the funds were used. Maybe they didn’t go in the right entity, but this is how they flowed. They made it to the project, the project used those funds. And so, they can get their acceptance. But that, again, like you said, it’s a mess. If it started from the beginning and everything was very clear, it wouldn’t come to that. But yes, we’ve done that before. We’ve done that.

Sam (33:47):
Jana, can you spend one minute talk about the ITIN, SSN? You know, what do people need to know about that? All of that.

Jana (33:56):
Yeah, sure. So something that’s, you know… like I said, you’re filing a partnership tax return, and you have foreign investors. So, until those individuals are a U.S. resident and they’re living here and they have their U.S. ID number, they need to have an ITIN. It’s an identification number that, as a partnership, you need to have to be able to file their tax returns or to file tax returns and give them a K1. It’s part of the following requirement. And, you know, obviously, it’s easy enough to make the application. It’s an identification number that would be put on the K1, and it corresponds to their name. And then, once they’ve received their… they’re in the US, they will get their U.S. number as well. But up until that point, it is important to have the investors receive an ITIN, and that can be done. We actually do that also in my office. We have someone certified that can meet over Skype and get that certification and get that ID number for the investor. But that’s a lot, that’s something where education… it’s important when educating the investor because they may not understand, why do I need a number or to be in the system, I’m not in the US yet, but it’s a matter of the tax compliance that’s needed.

Sam (38:30):
All right. So, thank you for that. So, now we’re going to open it up for… most of these look like they’re going to be for Jana. So, the first one is, “I thought there was a minimum or limit of $10 million for cash-based accounting.” In other words, if the project’s more than $10 million, it needs to be accrual-based— is that accurate? I don’t think so, but… Jana?

Jana (38:59):
I guess I’d have to look at the… you know what, there is a limit, but this is a strictly… these aren’t operational—they’re a loan and with equity. So, the limit is based on revenue generated. So, it’s a little bit different, the rules for that for cash basis. Yeah. It’s based on the revenue. And so, there’s different rules.

Sam (39:26):
Got it. Okay. Another question. If you have a foreign investor with an ITIN, do you have the F bar required?

Jana (39:37):
No. No. If you have a foreign investor who is a U.S. taxpayer and is considered a U.S. taxpayer because of the days inside the country and you’re filing still a 10 40 NR, you may have an F bar requirement, but not if they’re entirely not living in the United States or have any filing requirement.

Sam (40:04):
Then another question… well, we touched on this earlier a little bit—best accounting practices for I-829. You know, specifically, should each invoice be submitted with other evidential proof? We can, Mike and I can take that one. We’ve worked on a number of I-829 templates for Kolter projects and for others. And in general, you know, we’ll want to have detailed financials for the JCE entity showing all of the expenditures that were made. And we’ll typically want to have some individual invoices for major line items, like for steel, wood, major contractor expenses… some, you know, some people think you need to have every single invoice. We don’t think you need to have one for every single invoice, but you do need to have a detailed summary of the bank statements showing where money was paid and have it categorized for the jobs and then include, you know, at least a few sample invoices that tie out to some of those larger payments. And then, if there is a need for more invoices, you know, USCIS would request that in an RFE, but we haven’t… we’ve never seen that happen, where you’ve at least included a few and had the bank statements there. We haven’t had a situation where they asked for more. But obviously, you know, the more you have, the better to, you know, support the expenses that took place.

Sam (41:41):
So, how, in terms of expenses, Jana, how does that work? If I’ve got a project with 20 investors, and it’s a partnership, what am I looking at, roughly? You know, let’s assume that, you know, I’ve got a decent tracking in QuickBooks of loan payments and things, and I really just need help on the actual tax return and the filing. What is that going to cost, and how long does that typically take? And then, part two, if I needed that to be audited, what would that change? How would that change the cost, above just the tax return?

Jana (42:18):
Okay. You know, it’s a partnership with 20 investors or 20 partners, so that in itself does add some volume to the filing, with the allocations and addresses as such, but the inherent entity is really a loan, and the income it receives is interest income with some administrative expenses. So, there’s not a lot of line items [like with] your traditional business, with revenues and expenses you would see. So, there’s not a lot of activity that’s needed from a filing requirement. Also, from a timing perspective, most of these need to be finished, or the investors are very adamant about this and wanting to have these done by their filing date deadlines, if they need to be filed from an individual level. So we do these a lot at the very beginning of tax season, so that the investors themselves, the outside investors, will be able to file their tax returns timely.

Jana (43:23):
That being said, you know, it’s a very, you know, for about 20 partners, it’s going to be… don’t want me to do it, but like, you might have like a couple thousand dollars, probably, for a filing, $1500, $2000, maybe a little bit more, because you have foreign filings that are also required and possibly states at that point. But, again, that’s assuming, you know, you have very clean books and records, you keep everything internally, and then there’s just the filings that are needed. If you are looking for something as far as you can have a compilation report for your financials to provide to your investors, you can have reviewed financials or a full audit. Each of those financial statements coming from a CPA firm, you would only need one, but the compilation would have the least amount of review or reliance.

Jana (44:24):
It’s just, basically, your tax your information on a financial statement from your CPA firm, and those are relatively the less expensive. Then, if you needed more detail or want to have more things reviewed and tied out and reconciled, then that would be a reviewed financial. The highest level of assurance on any financial would be an audit. And then that would be a full audit and financial, and obviously, the most expensive. And it depends on, again, the number of partners, and, you know, different firms have different prices, but in range, you know, your compilation report may be somewhere between $1500, $2,500. Your reviewed financial, because of the additional work needed, would rise up between $12,000 to $15, $16,000. And then, obviously, an audit would be the highest level, which, again, would rise up to maybe about, I don’t know, $25, $30,000, maybe a little bit higher. And that’s just based on the detail of work that’s needed to test all of the cash coming in, to test the expenses, to pull samples of invoices. And so, there’s that assurance that everything in that, all those numbers in those financial statements have been tested.

Sam (45:49):
Got it. Got it. Thank you, Jana. I think, I think that’s it. We don’t have any other questions, so yeah. Thank you very much, Jana, for taking time to join us today. And if there are other questions that do come up for any of our attendees, please reach out to Jana—her contact information is on the screen. And any questions about structuring or regional center services related for EB-5 projects, please reach out to us—our contact info’s on the top right there as well. And yeah. Thank you very much for joining us today. Yeah. Thank you. And we will have a recording of this webinar, also, that will be added to our YouTube channel next week. So, if you were only able to join for part of it, or you want to share it or keep it on file when it’s tax time, you can find that on our channel as well. So yeah, we’ll wrap it up. Thank you, guys.

Jana (46:57):
All right. Thank you.