An E-2 investment funded from Turkey is often straightforward economically but difficult to evidence. U.S. immigration counsel may need a coherent record of where the capital originated, who controls it and how it was committed to the U.S. enterprise.
Reviewed 28 October 2026. Prepared by Evren Özmen, Licensed Turkish CPA (SMMM), TÜRMOB no. 35675. We provide Turkey-side accounting and tax support, not U.S. immigration legal advice.
Tell us the origin of funds, approximate investment size, timing and whether U.S. immigration counsel is appointed. Do not attach confidential records in the first message.
Short answer
Start with a narrative of the source of capital, then map every key movement to third-party evidence: original earnings or asset ownership, legal transfer or sale, account receipt, currency conversion and investment payment. A bank balance is a point in the chain, not necessarily the beginning. The U.S. Department of State does not prescribe a single universal list; the requested evidence depends on the case.
Step 1: classify the origin of funds
- Salary or professional income accumulated over time.
- Distributions from a Turkish corporation or limited company.
- Sale of shares in a Turkish enterprise.
- Sale of a Turkish property.
- Inheritance, gift or another lawful source.
- A mix of sources, where each strand needs its own history.
Step 2: build the evidence chain
- Origin: signed contracts, payroll or commercial records, purchase history, ownership certificates, tax returns where relevant.
- Right to receive: dividend resolutions, closing agreements, inheritance or gift records.
- Receipt: dated bank statements or payment confirmations matching the legal transaction.
- Transfer: incoming/outgoing bank entries and FX conversion tickets, including intermediary accounts.
- Commitment: U.S. investment receipts, transaction records or counsel-approved escrow evidence, as appropriate.
Typical Turkish documents by source
Dividends from a Turkish company
Trade registry information, financial statements, profit appropriation documents, shareholder resolutions, applicable tax returns and withholding records, plus shareholder bank receipt. Different legal forms require different corporate documentation.
Business or share sale
Ownership records, sale/purchase agreement, price settlement documents, evidence of the buyer’s payment and a tax review of the capital gain or other relevant taxes.
Property sale
Title ownership and transfer records, the sale contract/official deed as appropriate, documented settlement proceeds and any relevant taxable-gain analysis. Do not assume an advertised purchase price proves the amount actually received.
Savings and family transfers
Income history, bank savings accumulation, gift/inheritance documents and the continuity of account ownership. U.S. legal counsel evaluates which facts and documents are material.
Step 3: test the reconciliation
Create a simple ledger with date, payer, recipient, currency, amount, transaction purpose and supporting-document reference. Reconcile opening balances and any exchanges or charges. Investigate gaps and differences openly rather than forcing figures to match.
Illustrative source trail
A Turkish founder receives a legally declared distribution, transfers the net proceeds to a personal bank account, converts the funds into U.S. dollars, and pays part of the investment through a U.S. escrow account. Evidence should support each step. Escrow arrangements must be designed with U.S. counsel; merely placing funds in a personal account is not a committed investment.
What a Turkish accountant does — and does not — certify
A Turkish CPA can reconcile records and describe the Turkish factual and tax position. Only competent U.S. counsel can determine how the information should support a particular E-2 case. A financial schedule does not guarantee a positive consular outcome.
Frequently asked questions
Is there a fixed required statement period?
Not a universal period specified for all cases. The necessary history follows from the actual source and evidence requested by counsel.
Must the funds start outside the United States?
No. The State Department says the source of funds need not be outside the United States; lawful origin, possession/control and genuine commitment still matter.
Can an unsecured loan be included?
The treatment of loans is fact specific. The State Department explains distinctions based on the investor’s personal exposure and security; have immigration counsel review the structure before drawing conclusions.
For an engagement rather than a generic checklist, see our E-2 financial documentation service.
Tell us the origin of funds, approximate investment size, timing and whether U.S. immigration counsel is appointed. Do not attach confidential records in the first message.
Official references and editorial notes
- U.S. Department of State, 9 FAM 402.9 (E-2 Treaty Investors)
- IRS, Substantial Presence Test
- Systems CPA Editorial Standards
Turn Turkey compliance into certainty
SYSTEMS CPA supports foreign-owned companies with company formation, accounting, tax compliance and payroll in Turkey — one accountable local partner. Reviewed by Evren Özmen, SMMM (Certified Public Accountant), TÜRMOB Reg. No. 35675.
