A blog about U.S. immigration matters by Paul Szeto, a former INS attorney and an experienced immigration lawyer. We serve clients in all U.S. states and overseas countries. (All information is not legal advice and is subject to change without prior notice.)

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Monday, December 22, 2025

The Trump Gold Card Program - Ins and Outs

 




President Trump formally instituted the Trump Gold Card Program through the Executive Order 14351 in September 2025. This program offers a potentially fast-track route to U.S. permanent residency for foreign nationals.  Marketed as a "merit-based" overhaul, the program seeks to replace traditional, achievement-heavy evidentiary standards for the EB-1A (Extraordinary Ability) and EB-2 NIW (National Interest Waiver) categories with a direct financial contribution to the U.S. Treasury.  

The Cost of Entry: A Story of Two Cards

Under the new Gold Card Program, the path to residency is no longer based on outstanding achievements such as peer-reviewed articles or international awards, but with what the administration calls "unrestricted gifts" to the nation.

The Gold Card: Individual and Corporate Paths

An individual looking to secure a Green Card through the Gold Card program must first pay a non-refundable $15,000 processing and vetting fee just to open the door. Once the initial background check is cleared, the applicant is required to make a one-time, irrevocable gift of $1 million. If you are bringing a family, the math becomes aggressive: each dependent (spouse or child) requires their own $1 million gift and $15,000 fee.

For businesses, the Corporate Gold Card allows an employer to sponsor a key executive for a $2 million gift. A unique feature of the corporate version is "transferability"—if the original employee leaves the company, the corporation can potentially transfer the sponsorship slot to a new hire, though the new individual must still pass a separate $15,000 vetting process.

The Platinum Card: Coming Soon

The administration has also proposed the Platinum Card, designed for the ultra-wealthy who desire access to the U.S. without the full burden of its global tax system. For a $5 million contribution, participants are promised the right to reside in the U.S. for up to 270 days per year. 

The "crown jewel" of the Platinum Card is a proposed exemption from U.S. taxes on non-U.S. income. Traditionally, a Green Card holder is taxed on their worldwide income regardless of where they live. The Platinum Card proposes to allow participants extended stays without triggering the "Substantial Presence Test" that usually intertwines global assets in the U.S. tax net.


Legal and Procedural Issues

Despite the glossy rollout at TrumpCard.gov, the program's legal validity is still murky.  

Seperation of Power: The primary legal concern is whether the Executive Branch has the authority to effectively "sell" merit-based visas. The Immigration and Nationality Act (INA) defines EB-1A and EB-2 NIW based on specific criteria like "sustained national or international acclaim" or "national interest."  Can the Executive Branch rewrite the law - a power reserved for Congress - by treating million dollar gifts as a substitute for professional achievement?  The tax benefits proposed by the Platinum Card will also require changes in the Tax Code by Congress.

Litigation Risks: The Gold Card program may also be challenged in court by EB1A and EB-2 NIW applicants who cannot afford to pay the substantial fees.  Other affected parties, such as EB-5 program applicants, may also file lawsuits against the program.  If so, the pending cases could be frozen.  

Financial Risks:  Unlike the EB-5 program, where capital is "at risk" but theoretically returnable, the Gold Card requires an irrevocable gift and fees are likely non-refundable regardless of the outcome of the case.

Participate Now or Wait-and-See?

If you only have a "marginal" profile who might not otherwise win an EB-1A case, and you have $1 million in "disposable" capital that you are willing to lose in exchange for a chance at immediate processing, the Gold Card could be your solution. 

Whether one wants to participate in the Gold Card program now or later is an individual decision. Applicants should understand that the Gold Card does not create new visas; it uses the existing 140,000 annual employment-based quota. If there is a high volume of Gold Card approvals, it could worsen retrogression (backlogs) for traditional merit-based applicants, particularly for those from high-demand countries like India and China.

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