Obtaining the American Dream: EB-5 Million Dollar Investor Visas. Beverly Hills Bar Association, Business Law Section

Similar documents
Raising Money? Great! But Know the Legal Issues Involved

Practice Tips and Documentation for the Successful EB-5 5 Case

EB5 Program. Note: Investors may only be credited with preserving jobs in a troubled business.

Texas Blue Sky and Federal Securities Laws as to Oil & Gas Investments (or, We Are All Securities Lawyers Now, with apologies to Milton Friedman.

The Proposal: Considerations in Starting or Acquiring a Business

By: Wassem M. Amin, Esq., M.B.A. 1. In 1990, the United States Congress created the employment-based fifth preference ("EB-

EB 5 Investment in New and Existing Businesses 10/10/2011

A Primer on Securities Laws and Exemptions including recent changes made pursuant to the Jobs Act By Romana Kaleem, Esq. 1

IN-SOURCING" CAPITAL EB-5 LOANS AND EQUITY NMTC TAX CREDIT EQUITY NON-RECOURSE PROJECT FINANCE BONDS

2013 Wolfsdorf Immigration Law Group (all rights reserved) The contents of this document are proprietary and should not be duplicated or shared

MEMORANDUM. Re: Preliminary assessment of whether the Token GVT (Genesis Vision Token) which is CONTENTS A. BACKGROUND...2 B. QUERY:...

Forming a Regional Center and Other Options for Developers

Title 8: Aliens and Nationality PART 204 IMMIGRANT PETITIONS

What Constitutes a Security and Requirements Relating to the Offer and Sales of Securities and Exemptions From Registration Associated Therewith

2007 UPDATED LIST OF STATE SECURITIES LAW PROVISIONS THAT

For purposes of this chapter, including the application of the Bankruptcy Act to a liquidation proceeding:

The United States Government defines an alien as any individual who is not

ENROLLED ACT NO. 27, HOUSE OF REPRESENTATIVES SIXTY-FOURTH LEGISLATURE OF THE STATE OF WYOMING 2018 BUDGET SESSION

EB-5 Visas: Pitfalls and Benefits of U.S. Securities Laws

OVERVIEW OF SECURITIES LAWS

Foreign issuers often find that they would like to

First off, it s not really easy to get that equity. As a developer client told me a long time ago, You ve got to work hard if you want cheap money!

STAFF DRAFT FOR STAFF DISCUSSION PURPOSES ONLY NOT APPROVED BY ANY MEMBER OR FOR INTRODUCTION

The Wolfe Law Group Gary S. Wolfe, A Professional Law Corporation. March 18, Expatriation and the Ten Year Rule

THE F-1 VISA PRIVILEGED U.S. TAX STATUS AND HOW TO KEEP IT

STATE SECURITIES OVERVIEW: CAPITAL FORMATION UNDER BLUESKY

SEC Gives Green Light to General Solicitation and Advertising in Rule 506 Private Placements: EB-5 project issuers should proceed with caution 1

Mobility Matters When home is where the visa is, don t forget taxes are global

15 USC 78c. NB: This unofficial compilation of the U.S. Code is current as of Jan. 4, 2012 (see

The Application Process

Coming to America. U.S. Tax Planning for Foreign-Owned U.S. Operations. By Len Schneidman. Andersen Tax LLC, U.S.

EB- About the. Visa Description. The Perfect Network for Doing Business in USA

RAISING CAPITAL THROUGH PRIVATE PLACEMENTS: DEAL POINTS (Revised and Expanded)

Anthony Korda, Atty, The Korda Law Firm, Naples, Fla. Richard S. Lehman, Atty, United States Taxation and Immigration Law, Boca Raton, Fla.

EB-5 Investment Immigration to the United States

NEW JERSEY ANGEL INVESTOR TAX CREDIT FREQUENTLY ASKED QUESTIONS (FAQ) Updated 4/23/18

Investor Immigration Program EB-5 INVESTOR VISA

Launching a Hedge Fund: An Overview

Coming to America. U.S. Tax Planning for Foreign-Owned U.S. Operations. By Len Schneidman. Andersen Tax LLC, U.S.

15 USC 77b. NB: This unofficial compilation of the U.S. Code is current as of Jan. 4, 2012 (see

FATCA: Updates and Coordinating Regulations

LANDER S GUIDE TO THE U.S. CAPITAL MARKETS FOR U.S. AND FOREIGN COMPANIES AND THEIR ADVISERS

USCIS Policy Manual, Volume 6, Part G: Investors Job Creation and Capital at Risk Requirements for Adjudication of Form I-526 and Form I-829

Hatteras Core Alternatives Institutional Fund, L.P. Hatteras Core Alternatives TEI Institutional Fund, L.P. (the Funds )

Investments Overview: Regulation; Structures; Alternative Funds and Recent Developments

Legality of the Self-Directed IRA and Storage of Precious Metals

EXPAT TAX HANDBOOK. Non-Citizens and U.S. Tax Residency. Tax Year Ephraim Moss, Esq Ext 101

TAX CONSEQUENCES FOR U.S. CITIZENS AND OTHER U.S. PERSONS LIVING IN CANADA

"How to Become a US Resident through the EB-5 Investor Green Card Program. In cooperation with

What is an EB-5 Investment At Risk A Discussion of the Degree of Risk Required Mona Shah, Esq. Yi Song, Esq.

U.S. SECURITIES LAW ISSUES RAISED BY ACQUISITIONS BY NON-U.S. COMPANIES OF COMPANIES WITH U.S. SHAREHOLDERS

ENERGY FINANCE- UNLOCKING INNOVATION

ALI-ABA Course of Study Broker-Dealer Regulation

Toronto Young Practitioners Group

PART 2 OF FINANCING WITH ACRONYMS (Part 3 of Sidebar Financing Session) 2015 Seyfarth Shaw LLP _1.pptx 2

Page 129 of 1078 AAO PRECEDENTS IIUSA DOC# : USCIS EB-5 Training Materials (2012) Obtained by IIUSA via FOIA 10/

When Making Your Fractional Racing Ownership Business Plan, Don t Overlook the Securities Laws

AMERICAN JOBS CREATION ACT OF 2004

A. Understanding Regulation S

Securities, LLC. Deutsche Bank Securities

Tax planning for U.S. business operations of Indian enterprises

Term Sheet. Celernus Realty Income Properties LP October 28, Celernus Investment Partners Inc. (the Manager )

U.S. Estate Tax For Canadians

TECHNICAL EXPLANATION OF H.R

An Introduction to the US Estate and Gift Tax Regime

HOUSE BILL NO. HB0070

Ruben Flores, CPA & ATTORNEY THE FLORES GROUP Attorneys & Advisors

2600 N. Military Trail, Suite 206, Boca Raton, Florida Tel

EMPLOYMENT BASED FIFTH PREFERENCE (EB-5)

Summary of SEC Regulation S Dorsey & Whitney LLP

Instructions for Contract Between Sponsor and Household Member

Estate & Gift Tax Treatment for Non-Citizens

EXPATRIATION TAX AND PLANNING

U.S. Income Tax for Foreign Students, Scholars and Teachers. Arthur R. Kerr II Vacovec Mayotte & Singer LLP

International Planning

Practical guidance at Lexis Practice Advisor

AMERICAN CITIZENS ABROAD RESIDENCY-BASED TAXATION: A VANILLA APPROACH TO REPLACING CITIZENSHIP-BASED TAXATION

SUBJECT: Definition of Affiliate or Subsidiary for Purposes of Determining the H-1B ACWIA Fee.

International Tax and Asset- Reporting for the Everyday Client

CROSS-BORDER INCOME TAX ISSUES IN OUTBOUND ESTATE PLANNING. Jenny Coates Law, PLLC, International Tax Lawyer

AMERICAN CITIZENS ABROAD RESIDENCY-BASED TAXATION: A BASELINE APPROACH TO REPLACING CITIZENSHIP-BASED TAXATION

Distribution of Huntington Ingalls Industries, Inc. Common Stock Information Regarding Tax Basis as of April 1, 2011

FREQUENTLY ASKED QUESTIONS ABOUT REGULATION S

AMERICAN CITIZENS ABROAD RESIDENCY-BASED TAXATION: A BASELINE APPROACH TO REPLACING CITIZENSHIP-BASED TAXATION

Instructions for Form 8802

PRACTICAL TIPS FOR PRIVATE PLACEMENTS OF SECURITIES

What You Don t Know Will Hurt You

DR Advisor Whitepaper. Level I ADRs. A reference guide for issuers. November J.P. Morgan DR Group

Strategies for Documenting Lawful Source of EB-5 Invested Funds

AMENDED AND RESTATED CODE OF ETHICS FOR APOLLO INVESTMENT CORPORATION

SEC ADOPTS JOBS ACT PRIVATE PLACEMENT PROVISIONS: LIFTS BAN ON GENERAL SOLICITATION AND ADVERTISING IN PRIVATE PLACEMENTS

ScotiaFunds. Annual Information Form. January 18, Series I units of

ASSEMBLY BILL No. 1517

RAISING CAPITAL THROUGH PRIVATE PLACEMENTS: DEAL POINTS (Revised and Expanded)

TAX PLANNING FOR THE FOREIGN REAL ESTATE INVESTOR

D'Amico Family Wealth Management Group Of RBC Dominion Securities

Starting a Business in the US as a Foreigner

Estate Planning for the Multinational Family. Steven L. Cantor Cantor & Webb P.A., October 15, 2015

Form 8865 Reporting of Foreign Partnership Income and Navigating Rules for Allocable Share of Foreign Income

Regulation of Private Funds and Their Advisers Under the Dodd-Frank Wall Street Reform and Consumer Protection Act

Transcription:

Obtaining the American Dream: EB-5 Million Dollar Investor Visas Beverly Hills Bar Association, Business Law Section January 9, 2014

Leon Hazany Leon Hazany & Associates, APLC 5670 Wilshire Blvd., 17 th Floor Los Angeles, CA 90036 (323) 692-1446 Speakers Anibal Sanchez Darren Silver & Associates, LLP 3699 Wilshire Blvd., 6 th Floor Los Angeles, CA 90010 (213) 384-1900 Robin Mashal Century City Law Group, APC 1875 Century Park East, 6 th floor Los Angeles, CA 90067 (310) 286-2000

INDIVIDUAL INVESTORS (DIRECT INVESTORS) Leon Hazany, Esq.

Typical Scenarios: Individual Investors 1) Individual exploring U.S. Immigration Options meeting with immigration attorney to discuss immigration possibilities (Primary Goal is U.S. Immigration). 2) Investor starting a new business, purchasing existing business, or making some type of investment usually referred by Business Lawyer, CPA, Business Advisor or Real Estate Professional (Secondary Goal).

The Basics Conditional Lawful Permanent Resident Status ( Green Card ) can be granted (INA 203(b)(5)) 1) Invest in a New Commercial Enterprise 2) Investment Amount $1,000,000 (sometimes$500,000 may be enough) 3) Employs 10 U.S. citizens or authorized immigrant workers full-time (W-2) 4) Day to Day Management or Policy Formation

New Commercial Enterprise Must invest in a New Commercial Enterprise, which can be (8 C.F.R. 204.6(h)): A Company formed after 11/29/1990 Investor does not need to establish the company; only needs to invest in the company A Company formed before 11/29/1990, if: It has been restructured or reorganized so that a new commercial enterprise results; or Expanded so that there is a substantial change in the net worth or number of employees.

New Commercial Enterprise (cont d) Restructuring so that new commercial enterprise results must show Real Changes: Products or Services Offered Business Structure Manner Operated Organization of Employees Other substantial changes showing that new Business has resulted Change in Décor or Implementation of New Business Plan at Howard Johnson Motel not enough (Matter of Soffici) May Not create Net Loss in Employment (Matter of Hsiung)

Expanding Business 8 C.F.R. 204.6(h)(3) Requires 40% increase in: Net Worth; or Number of Employees. * Individual Investor must meet threshold Investment Amount $1,000,000 ($500,000), but for 40% test can include new investment funds into project by partners

The Investment INA 203(b)(5)(c): Invests $1,000,000, or Invests $500,000 if the investment is in a Targeted Employment Area (T.E.A.)

Forms of Investment - The investment can be in the form of cash, equipment, inventory, other tangible property, cash equivalents, and/or loans secured by the investor s personal assets (so long as investor is personally and primarily liable). - The Investment must be At Risk No Guaranteed Repayment - It is not okay to use loans secured by assets of the new commercial enterprise or retained earnings. - Value of capital is determined in U.S. dollars and at fair market value.

One Commercial Enterprise The investment must be in a single commercial enterprise not by combining investments into multiple commercial enterprises.

Source of Investment Funds Two Main Objectives: 1) Be certain the funds were legally obtained; 2) Be certain that the applicant is the one really investing their own funds.

Source of Investment Funds (cont d) U.S.C.I.S. will Trace the investment funds back to the source; They will want to see the paper trail for the investment funds; Examples of documentation: bank statements, wire instructions, personal tax returns, business tax returns, salary information, financial statements, loan documents, gift letters, asset purchase and sale records, proof of inheritance, etc.

Targeted Employment Area ( T.E.A. ) Question: When can the Investment Amount be $500,000 instead of $1,000,000? Answer: When the Commercial Enterprise is located in a Targeted Employment Area.

INA 203(b)(5)(A) Definition of T.E.A. 1) Rural Area (outside of a city or town having a population of 20,000+); or 2) High Unemployment Area (area that has experienced unemployment of at least 150% of the national average. U.S.C.I.S. can consider most recent Bureau of Labor Statistics or a State Designation (not designation by local government) Will look to the facts in existence at the time of the capital investment or filing of the I-526, whichever occurs first.

GO-Biz Governor s Office of Business & Economic Development (GO-Biz) http://business.ca.gov/programs/eb5program.as px Can help you determine if your Commercial Enterprise is located in a T.E.A. in limited cases by City or County, or in other cases by Census Tract.

Employment Creation Must Create Full-Time Employment for at least 10 qualifying U.S. citizens or immigrant workers within the 2-year Conditional resident (Green Card) period Full Time/ Permanent Employment (W-2) If the positions created are not all yet filled, U.S.C.I.S. will look to business plan to determine if nature and projected size of Commercial Enterprise will create need for not less than 10 qualifying employees

Employment Creation (cont d) Creation of Direct Jobs (between the Commercial Enterprise and Employees) Troubled Business Employment - Do not need to create the 10 new jobs, if it is a Troubled Business (where investment sustains current employees (at least 10) of a Commercial Enterprise which experienced a net loss for one or two years exceeding 20% of net worth)

Investor Involvement Investor will engage in Day-to-Day Business or Policy Formation, 8 C.F.R. 204.6(j)(5) Title and description of job duties Evidence of being corporate officer or director Powers are consistent with rights and powers normally granted for that position

Application Process Initially apply for 2-year Conditional Residency (Green Card) using U.S.C.I.S. Form I-526, and pay $1,500 application fee Submit extensive documentation showing that requirements met; Burden of Proof is on the investor Normally will work with a business plan writer as well as CPA for financial projections Current Processing Times on www.uscis.gov Once approved granted 2-year residency (Green Card) 90 days prior to expiration of 2-year residency, must file a Petition for Removal of Conditional Status (Form I-829) During I-829 process must demonstrate that: 1) required capital has been invested, 2) Sustained the enterprise and investment, and 3) created the requisite jobs

REGIONAL CENTERS EB-5 PILOT PROGRAM Anibal Sanchez, Esq.

What are Regional Centers? A Regional Center is an entity designated by U.S. Citizenship and Immigration Services ( USCIS ) which is involved with the promotion of economic growth, including improved regional productivity, job creation, and increased domestic capital investment. As of November 1, 2013, USCIS had approved approximately 400 Regional Centers. Regional Centers are part of the Immigrant Investor Pilot Program. The program has been authorized through September 30, 2015.

What are Regional Centers? (cont d) An immigrant investor may obtain permanent residence in the United States through a qualifying investment into a commercial enterprise operated or sponsored by a Regional Center. A commercial enterprise operating within a Regional Center receives the benefit of counting direct and indirect jobs towards the job creation requirement for each of its investors.

Obtaining Regional Center Approval An application must be made to USCIS on Form I-924 The application must include evidence of the following: The geographic scope of the proposed activity How the regional center will promote economic activity within the proposed geographic region Provide details on how direct and indirect jobs will be created through capital investment Provide information about the proposed project either hypothetical or actual project

Operating a Commercial Enterprise within a Regional Center Foreign investors must invest into a qualifying commercial enterprise operating under the auspices of an approved Regional Center. Regional Center approval from USCIS may be based on a hypothetical project or an actual project. Many Regional Centers establish projects within targeted employment areas to allow investors to qualify for EB-5 benefits through a $500,000 investment.

Operating a Commercial Enterprise within a Regional Center (cont d) Regional Centers generally will create commercial enterprises that are managed or owned by the Regional Center. Foreign nationals will in turn invest into the enterprise that is owned or managed by the Regional Center. Investments into EB-5 commercial enterprises are securities offerings and a PPM and related offering documents should be provided to investors

SAMPLE COMMERICAL ENTERPRISE STRUCTURE WITHIN A REGIONAL CENTER Regional Center EB-5 Investors EB-5 Commercial Enterprise

Submitting an EB-5 Investor Application Through a Regional Center Individual Investors must submit applications for EB-5 classification. The EB-5 commercial enterprise should provide each investor with evidence necessary to file their individual cases. This includes but is not limited to:

Submitting an EB-5 Investor Application Through a Regional Center (cont d) A EB-5 compliant business plan Evidence that the investment capital has been received and placed at risk by the commercial enterprise Evidence that the commercial enterprise is located in a TEA if investors are seeking to acquire their permanent residence through a $500,000 investment An economic analysis detailing how at least 10 direct and indirect jobs will be created for each investor Evidence that the foreign investor will participate in the management of the enterprise. A copy of the PPM and any other applicable offering or corporate documents

I-829 Processing For Investors Each investor must submit an I-829 application prior to the expiration of their 2 year conditional green card Evidence from the commercial enterprise that should be included in the application: Confirmation that the EB-5 investment capital has been utilized, or will be utilized, in a manner consistent with the business plan approved during the application process Evidence that the enterprise is operating as described in the business plan Evidence that at least 10 jobs have been created per investor.

BUSINESS LAW CONSIDERATIONS Robin Mashal, Esq.

Individual (direct) investor Corporate Law 1. Form business as a new commercial enterprise Entity formation Drafting charter documents, issuing shares Business permits Immigrant investor be engaged in management 2. Acquire existing business: Reorganize and restructure so it qualifies as a new commercial enterprise Due diligence - corporate law, tax law, liabilities Plan of reorganization

Corporate Law (cont d) Regional Center 1. New commercial enterprise Limited Partnership 2. Regional center applicant LLC or C Corp, and it acts as a GP of the LP 3. Regional center proposal to US Citizenship and Immigration Service (USCIS): Offering memorandum Statement of risk factors and disclosures Subscription agreement Limited partnership agreement Overall business plan (business plan writer) Economic impact analysis (economist) prediction on job creation, positive impact on regional and national economy; provide studies and analyses

Securities Law Federal and Blue Sky securities regulations apply to selling investments in regional centers Generally, any securities offered to the public must be registered unless exempted by rules Security: debt or equity instruments SEC Registration: expensive; for public companies Exemptions (safe harbors) Reg. D coordinated with state Blue Sky laws Reg. S Investor is advised about risks of investment

What is a Security The Securities Exchange Act of 1934 defines a security as: "Any note, stock, treasury stock, bond, debenture, certificate of interest or participation in any profit-sharing agreement or in any oil, gas, or other mineral royalty or lease, any collateral trust certificate, preorganization certificate or subscription, transferable share, investment contract, votingtrust certificate, certificate of deposit, for a security, any put, call, straddle, option, or group or index of securities (including any interest therein or based on the value thereof), or any put, call, straddle, option, or privilege entered into on a national securities exchange relating to foreign currency, or in general, any instrument commonly known as a security ; or any certificate of interest or participation in, temporary or interim certificate for, receipt for, or warrant or right to subscribe to or purchase, any of the foregoing; but shall not include currency or any note, draft, bill of exchange, or banker's acceptance which has a maturity at the time of issuance of not exceeding nine months, exclusive of days of grace, or any renewal thereof the maturity of which is likewise limited."

Rule 506 of Reg. D Rule 506 exempts (17 C.F.R. 230.506): Any issuer Offer and sell unlimited amount of securities No general advertising or solicitation To an unlimited number of persons No more than 35 un-accredited investors Each non-accredited investor has such business/financial knowledge and experience to evaluate the investment risk Required disclosures to non-accredited investors per Rule 502(b) Timely file Form D with SEC and pay the fee

Accredited Investor Accredited investor is a person whose: Net worth (alone or combined with spouse) exceeds $1M Individual income for past two years and current year exceeds $200K/year Joint income with spouse for past two years and current year exceeds $300K/year By limiting sales only to accredited investors, issuers avoid the need to make disclosures required under Rule 502(b)

25102(f) 25102(f) of Calif. Corporate Security Laws of 1968: Any offer or sale of security To 35 or less persons Purchaser has preexisting relationship with offeror, or has business/financial experience to have capacity to protect their interests For purchaser s own account No publication or advertisement File notice with Calif. Commissioner of Corporation and pay fee

Reg. S General requirements of Reg. S: 1. Offer and sale of securities in an offshore transaction Seller believes the buyer is offshore at time of transx. Transx. occurs in a designated offshore securities market (e.g. Canadian stock exchange) Transx. not pre-arranged with a buyer in the U.S. 2. No direct selling efforts in the U.S. Unlike Reg. D, complying with Reg. S does not provide an automatic exemption from state securities registrations. An issuer may simultaneously rely on Reg. S. (offshore offerings) and Reg. D (offerings within U.S.)

Employment Law Must create 10 full-time jobs for U.S. legal residents for each EB-5 investor: Employment Contracts Employee Handbooks Tax withholdings Employee benefits

Tax Considerations Tax ramifications of U.S. income/loss (including those from EB-5 investments) Nonresident Alien (person not U.S. citizen) subject to U.S. withholding taxes, unless they become a Resident Alien : Green Card Test includes conditional permanent resident Substantial Presence Test present in U.S. total 183 days over 3 years Resident aliens are taxed on worldwide income Effect of Tax Treaties Estate planning estate tax, gift tax, GST