Yes. EB-5 derivatives are the spouse and unmarried children under 21 regardless of nationality or Canadian status. Each must prove the relationship and admissibility in their own right, and a child's age is protected during petition processing under the Child Status Protection Act.
Relationship and age matter; passports do not
Unlike TN and E-2, EB-5 has no nationality requirement for the investor or the derivatives. A spouse of any citizenship and unmarried children under 21 may be included on the strength of marriage and birth records, and each undergoes the ordinary immigrant admissibility review. Hypothetical example: a retired Shannon engineer's wife holds a French passport and Canadian permanent residence, and their nineteen-year-old son holds Canadian PR through her; both are derivatives, and neither's lack of Canadian citizenship changes anything.
The son's age is calculated under the Child Status Protection Act, which subtracts the time Form I-526 or I-526E was pending from his age on the date a visa becomes available and requires him to seek residence within a year of that date; with a lengthy adjudication and any Visa Bulletin wait, the family should have the calculation run before filing. Derivatives receive conditional residence together with the investor and file the I-829 with him, or separately in defined circumstances. A child who marries before residence is granted loses derivative status.