Peter, for an E2 visa, when demonstrating that an investment is "substantial", how does the accounting work for intangible or in-kind contributions to the busin

Peter, for an E2 visa, when demonstrating that an investment is "substantial", how does the accounting work for intangible or in-kind contributions to the business? Is it possible to include the value of time spent building the initial product (while outside the US)? Does it make a difference if the applicant had a foreign company to do the initial development and paid themselves a salary?