Yes, if the land was lawfully acquired, the sales are documented and the net proceeds reach the qualifying amount. Land sales are an accepted source; the work lies in proving the chain from acquisition to closing.
Land is a lawful source when its history is documented
Hypothetical example: a Frontenac Islands farmer inherited a hundred acres from his parents, who bought it in the 1960s, and now sells three severed waterfront lots. The EB-5 source-of-funds rule asks how he came to own the asset that produced the money, not merely that a sale occurred. The estate file showing the transfer to him, his parents' original deed and any mortgage they carried, and the farm's tax history establish that the land was lawfully held.
The severance and sale documents show how it became cash. If the proceeds net of tax reach US$800,000 and the regional-center project is in a designated targeted employment area, the capital requirement is met; if the project is not in such an area, US$1,050,000 applies. The investment must also be at risk in a new commercial enterprise creating at least ten full-time jobs, and he must have a role in management or policy formulation, which a limited-partner interest with voting rights typically satisfies.
Hypothetical example: A Frontenac Islands owner sells a family-owned funeral home and intends to place the proceeds in a direct EB-5 enterprise. The first review should separate the lawful-source record from the enterprise’s job-creation record. Purchase records, tax returns, and closing statements settle how the money was earned; the business plan and payroll model address whether qualifying jobs can be created.
A large sale price alone does not establish either the required job outcome or the continuing exposure of capital to business risk.