Both offer permanent residence – in Canada and the U.S. respectively – to high net worth individuals in exchange for significant investment.
Here, we review the two programs and compare their advantages and disadvantages for high net worth candidates considering their residence-by-investment immigration options.
Compared: Quebec Investor vs U.S. EB-5
| QIIP | U.S. EB-5 | |
| Investment threshold | CAD $1.2 million (government guaranteed) | $500,000 (CAD$643,237) or $1 million (CAD$1.29 million) |
| Net worth requirement | $2 million | None stated |
| Nature of investment | Passive investment over 5 years bearing no interest | Investment in at risk project creating at least 10 jobs. For $500,000 threshold, investment must be in low-employment area (regional center) |
| Residence qualification | Immediate permanent residence | Immediate temporary residence, can apply for permanent after 2 years |
| Application window | The QIIP sets managed application periods, with the recent threshold set at 1,900 applications, including a maximum of 1,330 from China, Hong Kong and Macao. With families, the program welcomes 5,000 new permanent residents each year. The next application period is expected to open in Q3 2018. | The EB-5 issues a maximum of 10,000 visas per year to investors and their families. Upwards of 80% go to Chinese investors, with a large backlog creating a years-long waiting list for candidates from primary source countries. |
| Financing available? | Yes, formal financing schemes available | Program financing not permitted |
| Controversies | The main controversy surrounding the QIIP is that investors use it as a back door to Canada (Vancouver and Toronto). Despite attempts to make investors state their intention to reside in Quebec, once they have permanent residence status, they are free to move anywhere in Canada. The program has been blamed for inflating house prices in Vancouver and Toronto. | U.S. EB-5 projects have been beset with fraud, with several cases tied up in the U.S. legal system. Developers have also been accused of exploiting the system for determining what is a low employment area to pump investment into already thriving downtown areas. |
| Political climate | Canada’s political climate is stable and welcoming to new immigrants. | Under President Donald Trump, the U.S. has lurched towards protectionist politics, with the president pushing an anti-immigration agenda. |
| Program stability | The QIIP has just increased its investment and net worth thresholds for the first time in nearly a decade. The program is a well-established part of the Canadian immigration landscape. | The U.S. EB-5 program has not changed its investment thresholds since 1990 but is a continuous source of debate in U.S. politics. Lawmakers regularly call for the program to be scrapped, or for thresholds to be increased. With Donald Trump as president, the future of the program is uncertain. |
Conclusion
The Quebec Immigrant Investor Program features a stable, passive investment with a financing option in return for immediate permanent residence. With the popular financing option, the investment is approximately $325,000 (USD $260,000). It is not without controversies, but they are not a direct threat to the future of the program. With managed annual application limits, the program is well-administered and benefits both candidates and the Quebec economy. Provincial representatives from B.C. and Ontario would like to see the benefits shared, given how many of the QIIP candidates settle in their jurisdictions. Processing delays to visa issuance are near 44 months for Asian based investors.
The U.S. EB-5, in practice, features a significantly higher investment option and does not offer the stability and guarantees of the QIIP. The program operates by regular temporary resolutions, with the constant threat that it could be wound up, or investment requirements substantially raised. Processing times can be very long depending on one’s nationality. Chinese investors have to wait near 10 years for their applications to be approved. The attraction of a U.S. green card remains strong, however, making this the world’s most popular permanent residence-by-investment program.
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