No. The required amount is what is actually invested in the new commercial enterprise, at risk, in U.S. dollars on the date of investment. Estate costs, professional fees, the regional center's administrative fee and exchange losses are borne separately and do not reduce the required capital.
Only money that reaches the enterprise at risk counts
The EB-5 minimum — US$800,000 in a targeted employment area or infrastructure project, US$1,050,000 elsewhere, subject to statutory adjustment — is measured by the capital the investor actually contributes to the new commercial enterprise and places at risk for the purpose of generating a return. Costs incurred in obtaining or moving the money are not part of it: probate and notarial fees reduce what she inherits but do not count toward the investment; the spread on converting Canadian dollars is a loss she absorbs; the regional center's administrative or subscription fee is a separate payment for services, generally not at risk and generally not refundable, and must be paid on top. Government fees on Form G-1055 for the I-526E petition and the later I-829, State Department immigrant-visa fees for each family member, medical examinations and professional fees for the source-of-funds work are further columns.
She should plan the house sale and the estate distribution so that the net amount arriving in U.S. dollars exceeds the required investment with a margin, rather than discovering at the wire that fees have brought the total below the line.