“May I support my Form I-941 with evidence that the qualifying investment firm is controlled by U.S. citizens or residents without having to demonstrate that at least 50% of the capital is sourced from U.S. citizens or residents?”

The regulation defines the term “qualified investor” to include an organization that is located in the United States and operates through a legal entity organized under the laws of the United States or any state that is majority-owned and controlled, directly and indirectly, by U.S. citizens or lawful permanent residents (LPRs).  While USCIS does not require the applicant to establish that at least 50% of the capital contributed to the fund is sourced from U.S. citizens or LPRs, the applicant must nevertheless show that the fund is majority owned, directly and indirectly, by U.S. citizens or LPRs (which often corresponds with the amount of capital contributed).