At a glance
- The US Gold Card program is now operational — the official portal at trumpcard.gov accepts applications and DHS fees as of late 2025.
- Official pricing: $1 million per individual (or $2 million per corporate employee), plus a $15,000 non-refundable DHS processing fee per applicant. Each spouse and child under 21 requires an additional $1 million donation and $15,000 fee.
- The Gold Card grants US permanent residency (green card equivalent) with no job-creation requirement — a sharp departure from the EB-5 program.
- A higher-tier Platinum Card ($5 million) is listed as “coming soon” on the official portal. It would allow up to 270 days per year in the US and reportedly exempt foreign-earned income from US tax, though no enacted legislation supports the tax exemption yet.
- Gold Card holders face standard US worldwide taxation, FBAR, and FATCA obligations — a critical factor for high-net-worth clients in low-tax jurisdictions.
- A legal challenge (AAUP v. Trump, Case 1:26-cv-00300, D.D.C.) was filed on February 3, 2026, raising APA and INA arguments. No relief has been granted yet.
What is the US Gold Card?
The US Gold Card is a donation-based pathway to US permanent residency. Unlike the established EB-5 investor visa, the Gold Card does not require investment in a job-creating enterprise. Instead, applicants make a direct financial contribution to the US government — $1 million for individuals or $2 million for corporate-sponsored employees — in exchange for lawful permanent resident status.
The program was authorized by Executive Order 14351, published in the Federal Register on September 24, 2025. It represents the first time the United States has offered a donation-based immigration pathway, placing it alongside golden visa and residence-by-investment programs operated by countries such as Portugal, Greece, and several Caribbean nations offering citizenship by investment.
Program status: operational since late 2025
The Gold Card program is now operational. After months of uncertainty following the initial announcement in May 2025, key milestones have been reached.
- May 2025: Administration announces the Gold Card concept with an initial $5 million price point.
- September 24, 2025: Executive Order 14351 published in the Federal Register, setting the Gold Card at $1 million.
- November 19, 2025: Form I-140G receives OMB approval (control number 1615-0167). It is electronically fileable and currently set to expire May 31, 2026.
- December 10, 2025: The official portal at trumpcard.gov launches as the intake and application platform, accepting applications and $15,000 DHS processing fees.
- February 3, 2026: AAUP files a legal challenge (Case 1:26-cv-00300, D.D.C.).
- As of May 2026: Over 10,000 pre-registrations reported. The program continues accepting applications while the legal challenge proceeds.
The application flow works as follows: applicants submit through the trumpcard.gov portal and pay the $15,000 DHS fee, then undergo DHS vetting. After vetting clearance, the $1 million donation is collected through pay.gov. Applicants then file Form I-140G through myUSCIS (for adjustment of status) or Form DS-260G (for consular processing) to receive permanent resident status.
Gold Card vs Platinum Card
The administration has outlined two tiers. The Gold Card is active and accepting applications. The Platinum Card is listed as “coming soon” on the official portal.
| Feature | Gold Card | Platinum Card |
|---|---|---|
| Status | Operational — accepting applications | Coming soon (per official portal) |
| Donation amount | $1 million (individual) / $2 million (corporate) | $5 million |
| DHS processing fee | $15,000 per applicant (non-refundable) | Not yet published |
| Immigration benefit | Lawful permanent residency (green card) | Up to 270 days/year US presence |
| US tax treatment | Standard worldwide taxation, FBAR, FATCA | Foreign-earned income exemption reported — not yet enacted |
| Family inclusion | Each spouse/child under 21: additional $1M + $15k | Not yet published |
| Processing timeline | Competitors cite ~12 months as a benchmark | Reported at 270 days |
| Refundability | $1M donation and $15k fee are non-refundable | Not yet published |
How to apply: the I-140G process
The application process is structured in stages, moving from the official portal through DHS vetting and into the formal immigration filing system.
- Portal application: Submit through trumpcard.gov and pay the $15,000 DHS processing fee.
- DHS vetting: Background checks, source-of-funds review, and security screening. Vetting criteria are based on EB-1A/EB-2 NIW-comparable standards, with full financial disclosure required.
- Donation payment: After vetting clearance, the $1 million donation is collected through pay.gov.
- Immigration filing: File Form I-140G through myUSCIS for adjustment of status, or Form DS-260G for consular processing through the Department of State.
- Permanent resident status: Upon approval, the applicant receives lawful permanent resident status.
Form I-140G received OMB approval on November 19, 2025 (control number 1615-0167) and is electronically fileable. The current form authorization expires on May 31, 2026. Counsel should monitor whether USCIS extends or replaces it.
Family coverage and the corporate Gold Card
Each spouse and child under 21 can be included in a Gold Card application, but each family member requires a separate $1 million donation and $15,000 DHS fee. For a family of four (two parents and two minor children), the total cost would be $4 million in donations plus $60,000 in DHS fees.
A corporate pathway is also available at $2 million per employee. This is designed for companies seeking to relocate key personnel to the United States. Details on how corporate sponsorship interacts with the individual application process — and whether the sponsored employee’s family members require separate donations — remain to be fully clarified.
Gold Card vs EB-5: key differences
The Gold Card and the EB-5 investor visa serve different purposes and carry different risk profiles. Counsel advising high-net-worth clients should understand the core distinctions.
| Factor | US Gold Card | EB-5 Investor Visa |
|---|---|---|
| Legal basis | Executive order (presidential action) | Statutory (Congressional legislation) |
| Core requirement | $1M donation — no job creation needed | $800k–$1.05M investment + 10 full-time jobs |
| Refundability | Non-refundable donation | Investment can be returned after conditions removed |
| Tax treatment | US worldwide taxation | US worldwide taxation |
| Processing | New process — limited track record | Established framework since 1990 |
| Legal durability | Executive order — could be revoked by future president | Congressional statute — harder to revoke |
| Litigation risk | Active lawsuit (AAUP v. Trump) | Established legal precedent |
A key distinction for counsel: the Gold Card rests on executive authority, not statutory law. A future administration could revoke or modify EO 14351 without Congressional action. The EB-5 program, by contrast, is established by statute (INA §203(b)(5)) and has a three-decade track record of adjudication. Clients who value long-term legal certainty may prefer EB-5, while those who want speed and simplicity — and can accept the political risk — may favor the Gold Card.
Tax implications for Gold Card holders
Tax is the pivotal factor shaping demand. US permanent residents are taxed on worldwide income regardless of where it is earned. This applies fully to Gold Card holders, just as it does to EB-5 investors and any other lawful permanent resident.
Gold Card holders are subject to standard US tax obligations including FBAR (foreign bank account reporting) and FATCA (Foreign Account Tax Compliance Act) disclosure requirements. There is no special IRS guidance exempting Gold Card holders from any of these obligations.
The proposed Platinum Card has been reported to exempt foreign-earned income from US taxation, which would be a significant draw for globally mobile high-net-worth individuals — particularly those in low-tax or no-tax jurisdictions. However, no legislation enacting this tax exemption has been passed. Until enacted, counsel should not rely on the Platinum Card tax exemption in client planning.
For clients in the Gulf, Southeast Asia, and other regions where personal income is untaxed or lightly taxed, the worldwide taxation obligation substantially reduces the net appeal of the Gold Card. Counsel should model the full US tax exposure — including capital gains, trust distributions, PFIC/CFC implications, and state-level taxes — before advising clients to proceed.
Legal challenges: AAUP v. Trump
On February 3, 2026, the American Association of University Professors (AAUP) filed a lawsuit challenging the Gold Card program (Case 1:26-cv-00300, U.S. District Court for the District of Columbia). The complaint raises arguments under the Administrative Procedure Act (APA) and the Immigration and Nationality Act (INA), contending that the program exceeds executive authority.
As of May 2026, no injunctive relief has been granted and the program continues to operate. No additional executive orders have been issued beyond EO 14351, and no Congressional legislation has been enacted either supporting or limiting the program. The administration maintains strong support for the Gold Card, while opposition comes primarily from academic and advocacy organizations.
Counsel should factor litigation risk into client advice. If the program is struck down or modified by court order, applicants who have already donated may face uncertainty about refunds and status. The non-refundable nature of both the $1 million donation and the $15,000 DHS fee makes this risk particularly consequential.
Global context: how the Gold Card compares
The US Gold Card is now the most expensive golden visa–style program in the world. For comparison, other residence-by-investment and citizenship-by-investment programs require substantially lower contributions: Portugal’s Golden Visa starts at approximately $540,000, Greece offers options from $250,000 to $800,000, the UAE Golden Visa requires roughly $545,000, and several Caribbean citizenship-by-investment programs start at $200,000 to $250,000.
Armenia does not offer a donation-based residency program. However, Armenia’s residence by investment pathway and standard temporary and permanent residence permits provide alternatives for clients who want a base in the region without the tax exposure that comes with US permanent residency. Armenia’s flat 20% personal income tax for residents, combined with straightforward business registration (typically completed in 1–3 business days) and no minimum share capital requirement for LLCs, makes it a practical complement to a US strategy rather than a replacement.
For clients who are evaluating their global options, our team advises on Armenian tax structures, visa requirements, and digital nomad pathways alongside US and other international routes.
What counsel should do now
- Screen clients on readiness: net worth, liquidity timeline, source-of-funds traceability, and tolerance for evolving terms and litigation risk.
- Assemble source-of-funds documentation: multi-year bank flows, liquidity events, trusts, and corporate records to institutional standards. Pre-screen adverse media and sanctions risk.
- Model full US tax exposure: map worldwide income sources, holding structures (trusts, foundations, PFIC/CFC exposure), and FBAR/FATCA obligations before any US status change.
- Draft risk disclosures: highlight the non-refundable nature of the donation and DHS fee, the program’s executive-order basis, the pending AAUP lawsuit, and the possibility of policy changes.
- Monitor I-140G expiration: the current form authorization expires May 31, 2026 — watch for USCIS extensions or replacements.
- Plan contingency pathways: if terms narrow, quotas saturate, or the program is enjoined, have alternative routes ready — including EB-5, Armenia residence by investment, and other jurisdictions.
