ARTICLE
10 December 2025

Trump's "Gold Card": The Price Tag On The American Dream And U.S. Permanent Residency

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McCarthy Tétrault LLP

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As part of President Trump's sweeping U.S. immigration reform efforts this past year, the proposed "Gold Card" initiative has especially captured global attention.
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As part of President Trump's sweeping U.S. immigration reform efforts this past year, the proposed "Gold Card" initiative has especially captured global attention. Pursuant to a Presidential Proclamation issued on September 19, 2025, the Gold Card Visa Program was announced as a new pathway to U.S. permanent residence in exchange for a substantial unrestricted financial contribution to the United States.

The Gold Card signals a fundamental shift in the U.S. approach to economic immigration, explicitly linking permanent residence to a significant financial gift rather than traditional merit-based or employer-driven sponsorship.

Although the concept was announced earlier this year, implementation has accelerated following the submission of a draft Form I-140G by U.S. Citizenship and Immigration Services (USCIS) to the Office of Management and Budget (OMB) for mandatory federal review. OMB issued an emergency approval, a critical procedural step as agencies work toward a December 18, 2025, launch deadline set by the Presidential Order.

The Golden Ticket: Core Financial Requirements

Under the current proposal of the Gold Card, foreign nationals may qualify for an immigrant visa by making a significant, non-refundable financial gift to the U.S. Department of Commerce. The gift would be treated as evidence of exceptional business ability, national benefit, and eligibility for a national-interest waiver under existing employment-based immigrant visa categories.

At a high level, the Gold Card would permit U.S. permanent residence eligibility through the following gifts:

  • USD $1 million per individual applicant ("Trump Gold Card")
  • USD $2 million when the applicant is sponsored by a corporation ("Trump Corporate Gold Card")
  • USD $1 million per dependent

Unlike traditional investment-based immigration programs such as the EB-5 Immigrant Investor Program which requires a sizeable investment plus the creation of at least 10 U.S. jobs, the funds derived from the Gold Card are structured as a government gift, not as an investment tied to job creation, enterprise operations, or commercial return.

The Buy-In: Where the Gold Card Sits Among Employment-Based Green Card Options

The Gold Card does not create a new immigrant visa classification. Instead, it is designed to operate within some of the existing employment-based U.S. permanent residency framework: EB-1A (Extraordinary Ability) and EB-2 (Exceptional Ability and National Interest Waiver).

Under the proposed rules, the financial contribution itself would be treated as presumptive evidence of extraordinary ability, exceptional ability, and national benefit, significantly reducing the evidentiary burden and the heightened level of scrutiny applied to these classifications, both of which have intensified under the Trump Administration.

Importantly, however, the Gold Card does not bypass existing annual immigrant visa caps. Applicants remain subject to the Visa Bulletin and its fluctuating priority date movements which determine the wait time for an immigrant visa. Applicants from heavily backlogged countries (particularly China and India) may face a long wait for an immigrant visa. As a result, while the Gold Card reshapes qualification standards, it does not necessarily guarantee faster access to permanent residence.

The Road to Gold: How the Process Is Expected to Unfold

Based on the current version of draft USCIS materials, the expected process would proceed as follows:

  1. Initial Gold Card application submission to the Department of Commerce and filing of Form I-140G with USCIS, which will assess EB-1 or EB-2 NIW eligibility
  2. Payment of a non-refundable filing fee in the amount of USD $15,000 via pay.gov
  3. Vetting of "lawful source of funds" conducted by USCIS, which may include support from other federal agencies as needed

Upon approval and once a visa number becomes available, applicants residing outside the United States would complete standard immigrant visa processing through a U.S. consulate. While not yet confirmed through formal guidance, it is anticipated that applicants already in the United States would be eligible to apply for an adjustment of status, consistent with existing employment-based immigration categories.

Following the Money: Enhanced Financial Transparency and Cryptocurrency Oversight

The proposed Gold Card application process facilitated by filing Form I-140G introduces exceptionally rigorous financial disclosure requirements, including a detailed list of all personal and spousal financial accounts; full disclosure of cryptocurrency holdings; complete path-of-funds tracing to the Department of Commerce; and documentary evidence that all gifted funds were lawfully obtained.

Where cryptocurrency is involved, the form expressly requires blockchain traceability; wallet identification; transfer through a regulated financial institution, and any additional supporting evidence upon request by USCIS. Applicants are expected to complete extensive self-attestation declarations addressing fraud, money laundering, sanctions exposure, terrorism, and national security risks.

Corporate Sponsorship Obligations

Where a corporation sponsors a Gold Card applicant, USCIS is expected to require three (3) years of U.S. federal corporate tax returns; audited financial statements and/or annual reports; proof that corporate funds were lawfully sourced and transferable; and full disclosure of ownership and financial control.

These requirements significantly elevate the corporate compliance and governance burden relative to traditional employment-based immigration filings.

What Comes Next

The Gold Card program has not officially launched. However, interested applicants may join a waitlist now, and applications will be processed on a first-come, first-served basis once the program opens.

Additional guidance is expected from USCIS and the Department of Commerce in the coming weeks as agencies work toward the December launch target.

Separately, the Trump Administration has publicly referenced a "Platinum Card" concept that would permit qualifying individuals contributing USD $5 million to reside in the United States for up to 270 days per year without U.S. tax exposure on non-U.S. income. Further details are expected to be released.

Closing Perspective

The Gold Card represents one of the most explicit attempts in modern U.S. immigration history to monetize access to permanent residence. While technically structured within the EB-1 and EB-2 employment-based immigration framework, its extraordinary cost, aggressive compliance standards, and unchanged visa backlog realities raise meaningful questions about its long-term commercial viability.

Compounding this uncertainty is the fact that the program could be materially altered, curtailed, or dismantled altogether by a future administration, particularly if implemented through executive authority rather than congressional action.

For now, the program appears calibrated for a narrow segment of high-net-worth individuals and corporations willing to assume and absorb both the financial and regulatory risk associated with an untested immigration model.

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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.

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