On September 19, 2025, the White House issued an executive order establishing the “Gold Card” program. This “Gold Card” differs from the program introduced in February 2025.
Under the order, individuals (or sponsoring corporations) may qualify for an expedited immigrant visa process by making a donation of $1 million (individual) or $2 million (corporate) to the U.S. government. The program directs agencies to treat such contributions as evidence of exceptional business ability and national benefit, effectively enabling participants to bypass traditional eligibility hurdles under existing employment-based visa categories. Funds received will be deposited in a dedicated Treasury account and used to promote American commerce and industry.
The “Gold Card” will not exempt individuals from taxation on worldwide income as initially introduced.
While implementation is set to occur within 90 days, the order raises significant constitutional, statutory, and policy concerns. Litigation challenging the legality of the program is widely expected, and clients should closely monitor both the legal challenges and the forthcoming regulatory framework that will govern applications under this new initiative. Additionally, it is expected that a “Platinum Card” may be introduced in 2026 that would require a government donation of $5 million and would allow individuals who spend less than 270 days in the US to be exempt from tax on worldwide income. The administration has agreed that this program would require congressional approval before being put into law.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
