There is no fixed percentage, but the investment must be substantial relative to the business's value and the funds counted must be the buyer's own or personally secured. A closing built mostly on seller financing weakens the case.
Set the cash-at-closing to satisfy the proportionality test
Hypothetical example: the agreed price is met forty percent in cash at closing and sixty percent by a seller note secured by the company's receivables and vehicles. Only the cash, plus any personally secured borrowing, is likely to be treated as at-risk investment, and forty percent of the value of an established business may or may not be substantial depending on the numbers. Two adjustments help: increase the cash portion, or secure the note against the buyer's own Canadian assets so the buyer, not the enterprise, carries the risk. Beyond the price, budget for the consular application and the visa fee published by the State Department, the lawyer and accountant on the deal, the state licence transfer, insurance, and working capital, some of which can also be counted as invested once committed. Ask the seller for the true cost of running the business for six months so the working-capital figure is real rather than guessed.
Hypothetical example: a window-restoration company requires a van, specialized tools, insurance, and a leased workshop, but the investor budgets only the seller's asking price for customer lists. The relevant calculation is the total cost of the operating enterprise and the proportion of it placed at risk, not a headline purchase price in isolation. At intake, separate capital committed to the business from application charges, moving costs, and personal rent. Obtain signed quotes, lease terms, and insurance binders before deciding how much cash must be committed. A business can be too lightly funded even where the investor has substantial savings elsewhere. It also can fail the marginality analysis if the plan has no credible route beyond supporting the investor and family.