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MARKSTAY-WARREN · EB-5 FIELD GUIDE

What if the parent’s sale proceeds passed through more than one account?

Sources checked:

THE DIRECT ANSWER

Document the intermediate accounts and transfers with dates, amounts and account-holder information. Do not skip an account because the money stayed there briefly.

Explain differences without rewriting the history

Reconcile conversion, fees or split transfers using the actual records. If another family member received or forwarded funds, identify that person’s role and the legal arrangement rather than describing an uninterrupted direct gift. Request missing institutional records and disclose genuine gaps. A diagram may help a reviewer follow the transaction, but it is not a replacement for evidence of the underlying source and path.

The subscription agreement states the capital required; the foreign-exchange confirmations and the outgoing wire advices state what was actually delivered and on which dates; the escrow or enterprise account statements show receipt. Documents covering the whole history of the value, not just its final form: corporate ownership records, auction and property sale documents, loan discharges, tax filings across the years, and an unbroken bank trail into the enterprise. Evidence that the proceeds lawfully moved from the corporation to you: a directors’ resolution declaring a dividend or approving a shareholder loan, the corporate bank statement showing the payment, and your personal statement showing receipt.