No. Substantiality is proportional to the cost of this particular business, and the amount must be enough to make the investor's commitment credible. Government and professional charges are separate from the investment.
Proportion and commitment, not a threshold
The E-2 rules deliberately avoid a dollar minimum. The substantiality test asks whether the amount invested is substantial in relation to the total cost of purchasing or creating the enterprise, and whether it is large enough to show the investor's financial commitment and likelihood of success. Paying the full price for a majority of an operating coatings contractor with crews and equipment usually satisfies that test; a token deposit with the balance due on visa approval does not.
Keep three budgets separate: the investment itself, which must be at risk in the business; working capital the buyer holds in reserve, which is not counted until committed; and the consular application fee, professional fees and translation costs, which are never part of the investment. Take the consular fee from the State Department's current schedule and any USCIS change-of-status fee from the G-1055 schedule. A larger price does not cure a control problem in the shareholder agreement.