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[HOT] [Q] Are new employees of retail tenants indirect or direct jobs of the EB-5 project?


Employees of retail tenants of a new shopping center project do not appear to fit neatly into any of the below definitions. I would think they have to be defined as "direct" jobs, but USCIS has yet to provide a clear answer to the question of where these jobs fall under.

Direct jobs are those jobs that establish an employer-employee relationship between the commercial enterprise and the persons that they employ. Regional centers typically use the RIMS II or IMPLAN economic models to determine the number of indirect jobs that will be created through investments in the regional center’s investment projects.
Indirect jobs are the jobs held by persons who work for the producers of materials, equipment, and services that are used in a commercial enterprise’s capital investment project, but who are not directly employed by the commercial enterprise, such as steel producers or outside firms that provide accounting services.
There is a sub-set of indirect jobs that are calculated using economic models that are known as induced jobs. Induced jobs are those jobs created when direct and indirect employees go out and spend their increased incomes on consumer goods and services.