01
The challenge
USCIS questioned the petition's job creation, economic impact, scalability, financial projections and funding. The client needed a signed, independent letter of up to five pages answering each item. She had no Excel model, only the PDF plan, and the plan was already filed with USCIS, so its numbers could not simply be changed.
02
Our approach
- Rebuilt the model from the PDF. All nine schedules (revenue, payroll, payroll taxes, operating costs, income statement, cash flow, NPV and payback) were recalculated and agreed back to the plan.
- Stress-tested the assumptions. Staffing was tested against projected delivery hours, pricing and wages against cited BLS data, and NPV at a higher risk-adjusted discount rate.
- Our own tax figures. Federal and California income and payroll taxes were computed independently; sales tax the plan had applied to non-taxable services was excluded.
- Private pre-review memo. Findings went to the client first with two options: keep the filed plan and let the letter state our independent figures, or revise the plan with counsel. She chose the first.
- Item-by-item letter. Each section answered one RFE item, with weak points (a non-binding letter of intent, an uncommitted funding tranche) disclosed in neutral language.
03
Results delivered
- A signed four-page CPA assessment letter on firm letterhead, delivered on schedule after client review.
- A defensible, independently computed tax and economic contribution figure.
- A private findings memo and an internal file memo documenting every discrepancy and its treatment.
04
Frequently asked questions
Yes. A licensed CPA can independently assess a business plan's projections, job creation estimates and economic impact. USCIS weighs it as expert evidence alongside the rest of the petition.
The CPA can rebuild the model from the PDF schedules, but this adds time and cost, so mention it when you request a quote.
No. A signed CPA letter can be limited in scope, but it cannot omit or misstate material findings. Issues are best shared privately first so you can decide how to address them.
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