On September 19, 2025, U.S. President Donald Trump issued an executive order outlining two proposed investor-focused immigration concepts referred to as the Gold Card and the Platinum Card. Both initiatives would invite ultra-high-net-worth individuals to make substantial financial contributions to the U.S. government in exchange for enhanced residence privileges.
Despite the attention generated by the announcement, neither proposal is currently operational. Federal agencies have been directed to develop regulatory frameworks within ninety days, and both initiatives face significant legal and structural barriers before they could become practical immigration options.
How the Gold Card Would Work
The Gold Card proposal would allow an individual to make a $1 million contribution to the U.S. Department of Commerce. Following security screening and confirmation that an immigrant visa number is available, the applicant could pursue permanent residence through existing employment-based immigrant visa categories, including EB-1 or EB-2 with a national interest waiver.
A corporate version of the Gold Card would increase the required contribution to $2 million per sponsored employee and introduce annual maintenance fees. Under the proposal, a sponsoring employer could transfer the benefit to another employee if the original beneficiary leaves the company. Detailed eligibility rules, documentation standards, and processing criteria are expected to be published by the Departments of Commerce, State, and Homeland Security.
What the Platinum Card Proposes
The Platinum Card is positioned as a higher-tier concept requiring a $5 million contribution. Early descriptions suggest it could allow the holder to spend up to 270 days per year in the United States while maintaining a form of long-term residency status. Unlike traditional immigrant visas, the Platinum Card is not presented as a direct route to U.S. citizenship.
The most notable feature of the Platinum Card proposal is tax related. It suggests a holder could remain in the United States for up to 270 days without triggering U.S. global tax residency. Under current law, this is not possible.
Legal and Tax Considerations
Both initiatives rely on executive authority, which allows federal agencies to establish procedures but does not permit changes to immigration or tax law.
The Gold Card proposal attempts to operate within existing employment-based immigrant visa categories. While this approach could allow agencies to proceed through formal rulemaking, any regulations must remain within the authority granted by Congress and could face legal challenges if they are viewed as creating a new visa category in practice.
The Platinum Card faces a higher hurdle. Its proposed tax benefit conflicts directly with the current substantial presence test under U.S. tax law. Implementing this feature would require new immigration and tax legislation passed by Congress and signed into law.
Implementation Timeline and Open Questions
The executive order instructs the Departments of Commerce, State, and Homeland Security to publish application procedures and regulatory guidance within ninety days. Until those regulations are released, there are no filing mechanisms, start dates, or confirmed adjudication criteria.
Future rules are expected to clarify how contributions are verified, how security and admissibility standards will be applied, how visa number availability will be assessed, and how corporate sponsorship transfers would function.
Market Reaction and Practical Reality
Industry response has been cautious. Many advisors question whether investors will commit a non-refundable $5 million contribution solely to extend time in the United States without triggering worldwide taxation.
In practice, affluent families already rely on established non-immigrant visa strategies and tax planning tools that allow them to spend approximately 182 days per year in the United States without becoming U.S. tax residents.
Established Investor Pathways Remain
While these proposals develop, existing investor immigration options remain unchanged. The EB-5 Immigrant Investor Program continues to operate under the EB-5 Reform and Integrity Act of 2022, with minimum investment thresholds set at $1,050,000 or $800,000 for qualifying projects. The program requires the creation of at least ten full-time U.S. jobs and includes inflation-based adjustments scheduled to begin on January 1, 2027.
Outlook
The Gold and Platinum Card initiatives remain proposals rather than actionable programs. Their future depends on forthcoming federal regulations and, in the case of the Platinum Card, new legislation passed by Congress.
Until those steps are completed, investors and advisors should treat these announcements as conceptual and continue to rely on established, legally tested immigration strategies.
To learn more about established citizenship by investment options available today, or to stay informed as new programs develop, we invite you to connect with our team.
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