Inside The Gold Card Program: U.S. Residency for Private Clients

(UNITED STATES) President Donald Trump on September 19, 2025, signed an executive order creating the Trump Gold Card, a new U.S. residency path that would offer expedited lawful permanent residence in exchange for large contributions to the federal government, with implementation instructions aimed for completion by mid-December. The program, unveiled through a presidential proclamation alongside the order, targets high-net-worth individuals, family offices, and multinational employers that want a faster route to green cards for themselves or select employees. The White House framed the initiative as a way to raise more than $100 billion for future tax cuts while opening a premium lane within the immigration system, though immigration attorneys and corporate mobility leaders say the lack of published procedures and the reliance on executive authority leave crucial questions unanswered.

How the program is described

Under the plan as described by administration materials and legal analysts:

• Individuals could secure permanent residence by making an unrestricted $1 million contribution to the U.S. Department of Commerce, plus a nonrefundable processing fee and full Department of Homeland Security (DHS) vetting.
• A corporate track would allow employers to sponsor key staff for permanent residence by contributing $2 million per employee, also with a processing fee and security checks for each beneficiary.
• Employers may be permitted to transfer a sponsored Gold Card to another worker if the original beneficiary departs, paying a transfer fee and completing new vetting without repeating the $2 million contribution.
• Officials have signaled an annual maintenance fee will apply to each card, though the exact amount has not been published.

Timing, implementation, and current status

The executive order directed the Commerce Secretary to produce detailed application procedures within 90 days, making mid-December 2025 the target for guidance on:

1. How to submit payments.
2. What documentation will be required.
3. How USCIS and DHS will coordinate background checks and adjudications.

As of November 7, 2025, this guidance had not been released. A preliminary website, trumpcard.gov, hosts high-level information and a sign-up list for updates, including a waiting list for an even costlier option that remains only a proposal.

Interaction with existing visa categories

The Trump Gold Card is designed to interact with existing immigrant visa categories rather than create a new visa number source. Administration materials suggest the contribution would qualify applicants for priority handling in employment-based categories such as:

• EB-1A (extraordinary ability)
  • USCIS guidance: EB-1, Extraordinary Ability
• EB-2 National Interest Waiver (NIW)
  • Typical NIW requirements: substantial merit and national importance, and showing benefit to the U.S. by waiving a job offer and labor certification

When applicants proceed to permanent residence:

• Those inside the U.S. would use Form I-485 (Adjustment of Status): Form I-485
• When an underlying immigrant petition is involved, employers or self-petitioners commonly rely on Form I-140: Form I-140

Attorneys note that some familiar immigration steps—petition filings, adjudications, adjustment or consular processing—would still apply even with the Gold Card’s priority handling.

Support, opposition, and political context

Supporters inside the administration argue the program:

• Serves as both a funding tool and a way to compete for global talent.
• Would capture capital and skills that might otherwise go to Canada 🇨🇦, Europe, or the Gulf.

Opponents on Capitol Hill contend the plan:

• Skirts Congress and risks turning green card access into a transactional exchange favoring wealth over merit or family ties.
• Faces legal and political vulnerabilities because it rests on executive authority rather than statute.

“The Gold Card program prioritizes speed, capital, and access for a narrow set of applicants, primarily high net worth individuals, family offices, and employers managing cross-border mobility,” said Grace Shie, who leads the Global Mobility practice at Mayer Brown.

Morgan Bailey, Mayer Brown partner, added that demand is strong even as firms seek firm rules: “We’ve already had a lot of clients reaching out with questions. Proactive planning will be essential as the landscape of U.S. immigration and taxation continues to evolve.”

Platinum Card proposal and tax implications

The administration also proposed a potential offshoot, the Platinum Card:

• Would require a $5 million contribution.
• If authorized by Congress, could allow recipients to spend up to 270 days per year in the U.S. without being subject to federal tax on non-U.S. income.
• As of November 2025, this remains inactive and would require legislation and regulations to implement.

Important tax distinctions:

• Gold Card recipients proceeding to permanent residence would be subject to U.S. taxation on worldwide income, like all lawful permanent residents.
• The Platinum Card’s tax benefit is contingent on congressional action and is not part of the current program.

Vetting, admissibility, and security checks

The administration emphasized that DHS vetting remains mandatory for every applicant. Key points:

• Background reviews will cover criminal history, prior immigration violations, and national security concerns.
• The contribution does not guarantee approval; it buys an accelerated lane, not immunity from inadmissibility grounds.
• Standard processes—interviews, requests for evidence, medical exams with civil surgeons for adjustment applicants—still apply.

Attorneys expect anti-money laundering and “source of funds” documentation similar to EB-5 practice, potentially including:

• Bank letters
• Wire confirmations
• Records proving lawful origin of funds

Operational questions and practical concerns

The executive order delegates detailed design choices to the Commerce Secretary and DHS, which raises operational questions:

• Will contributions be escrowed pending vetting?
• How will refunds be handled if an application is denied or an agency error occurs?
• What appeal routes exist if a case is denied after payment?
• How will the transfer fee work for corporate sponsors, and how long can a Gold Card remain dormant between assignees?
• Will the annual maintenance fee be fixed or inflation-indexed?

Stakeholders expect agencies to rely on existing immigration infrastructure, but the timing and sequencing—Commerce intake and payment portal vs. DHS/USCIS guidance—remain uncertain.

Employer considerations and workforce impacts

For multinational employers, the $2 million per employee route could be attractive where:

• Delays harm product cycles or business continuity.
• Moving a few high-impact staff into permanent roles quickly provides measurable benefits.

Potential employer concerns:

• Internal equity issues: paying for premium paths may require new policies to explain who qualifies and why.
• Coordination between global mobility teams and outside counsel to manage evidence, public charge issues, and security vetting.
• Need for clarity on transferability mechanics and maintenance fees.

Comparisons with EB-5 and other options

Key differences vs. EB-5 investor program:

• Gold Card contribution is a gift to the government with no direct return, unlike EB-5 where funds are invested in projects.
• EB-5 thresholds vary (typically $900,000 to $1.8 million depending on location) but require job creation and may involve longer adjudication times.
• Gold Card pitches simplicity and speed for a higher nonrefundable cost.

Advisors are weighing the certainty of cost against timing uncertainty and tax obligations. The Gold Card’s tax profile (standard worldwide taxation for LPRs) contrasts with the Platinum proposal’s potential tax advantage — which remains dependent on Congress.

What applicants should do now

Practical attorney and mobility-manager advice:

• Do not move money or make irreversible plans until the government publishes official procedures.
• Appoint legal counsel early.
• Assemble documentation proactively:
  • Proof of funds/source-of-funds documentation
  • Passports and travel history
  • Prior U.S. filings
  • Evidence suitable for EB-1A or EB-2 NIW, if applicable
• Monitor trumpcard.gov for updates but rely on Commerce and USCIS notices for substantive rules.

VisaVerge.com analysis notes firms are building client checklists but caution that plans should include contingencies for litigation or policy reversals.

Likely rollout scenarios and risks

• If agencies meet the 90-day deadline, the first quarter of 2026 could see initial approvals.
• Delays or early litigation could slow or complicate implementation.
• The program’s reliance on executive authority exposes it to potential reversal by future administrations or congressional action.

The more the order ties into established statutory categories like EB-1A and EB-2 NIW, the harder it may be to dismantle quickly—though processing priorities and fee structures could be changed.

Final takeaways

• The Trump Gold Card is a high-cost, expedited pathway pitched to wealthy individuals and employers in exchange for large, nonrefundable contributions.
• Many practical, procedural, and legal questions remain unanswered until Commerce, DHS, and USCIS publish implementing guidance.
• Potential applicants should prepare documentation and legal representation now but avoid irreversible actions until official rules and portals are live.
• The program mixes promise (speed, priority handling) with uncertainty (litigation risk, tax realities, and operational gaps), and its durability will depend on legal challenges and future political shifts.