The White House officially launched the “Trump Gold Card”[1] on December 10, 2025, opening an expedited pathway to green cards for individuals and companies willing to invest substantial funds, but the future of the program will likely be challenged by litigation.
What are the Trump Cards?
Trump Cards provide expedited immigration pathways to foreign nationals based upon substantial “gifts” to the US government. The cards are divided into three categories: the individual Gold Card, the Corporate Gold Card, and the individual Platinum Card, the latter of which remains pending. Each category requires:
- a $15,000 non-refundable processing fee paid to the US Department of Homeland Security (DHS) and
- a “gift” to the US government, with the required amount varying by card type.[2]
This contribution, or “gift,” does not reflect the value of any private investment in the US economy; rather, it is characterized as “evidence that the individual will substantially benefit the United States,” and will be managed by the US Department of the Treasury. All applicants must meet US government requirements and participate in an interview prior to approval. There will also likely be legal challenges to these programs but no indication that the processing fee would be refunded if a program is invalidated.
Trump Gold Card
The Trump Gold Card is an individual visa program for investors who “gift” the government $1 million upon DHS approval; “the process for petition approval and visa adjudication will take place on an expedited basis, assuming applicants submit any additional documents or fees in a timely manner.” Each dependent (spouse and child under 21) will trigger an additional $1 million gift and $15,000 processing fee. One key difference between current investor-based green cards, like the EB-5 program, and the Trump Gold Card is no mandatory job-creation requirement tied to the investment.
Trump Corporate Gold Card
Eligible corporate sponsors may sponsor an employee with a required gift of $2 million. For this card, the $15,000 processing fee is required for each sponsored employee, and sponsors may apply for multiple employees at once. Upon approval for each employee, the sponsor will be required to pay a gift of $2 million per sponsored employee as evidence that “the employee will substantially benefit the United States.”[3] There does not appear to be an annual maintenance fee affiliated with the individual card.
The Corporate Gold Card, in contrast to the individual Gold Card, is transferable among sponsored employees. Corporate sponsors “may cease sponsoring one employee and use the gift contribution tied to the prior application as a basis for sponsoring a new employee, without a new $2 million gift.” Any transfer of sponsorship will incur a 5% transfer fee from which the cost of a new DHS background check will be deducted. Corporate Gold Card holders are also subject to an annual maintenance fee of $20,000 per sponsored individual.
Trump Platinum Card (coming soon)
Although the Trump Platinum Card has not yet been launched, foreign nationals may currently sign up for a waitlist. When applications open, the same DHS processing fee of $15,000 applies, with a “gift” of $5 million, granting cardholders “the ability to spend up to 270 days in the United States [per year] without being subject to US taxes on non-US income.”[4]
Notably, there is “no assurance that the Platinum Card contribution will remain at $5 million,” so prospective applicants are encouraged to join the waitlist to secure eligibility for the first round of applications at the current contribution level. Litigation is also anticipated related to the availability of this card.
Tax Status
Trump Gold Card holders will be subject to US federal income taxation, including on income earned outside the United States. Although there is no formal guidance on the applicability of US federal estate and gift taxes under this program, Trump Gold Card holders should carefully consider their time spent in the United States and connections to the US as they may be considered domiciliaries of the United States and therefore be subject to the US federal gift and estate tax and reporting regimes on a worldwide basis.
As noted above, the appeal of the Platinum Card, once launched, is the claim that it will enable recipients to spend 270 days per year in the US without being subject to US federal income taxes on non-US income. However, this should be carefully monitored as the rules surrounding the taxation of Trump Card holders is continuously evolving.
Interested in exploring Trump Card options?
The Trump Card programs offer additional options for foreign nationals interested in permanently or temporarily residing in the United States who are willing to provide substantial monetary gifts in exchange for a streamlined evidentiary burden based on a presumed national benefit. Interested applicants should be wary of the likelihood of litigation challenges to the long-term success of these programs.
- Selected quotations from the Essential Information and Guidance provided at trumpcard.gov appear in this alert to support the information presented.
[Back to reference] - Additional routine processing fees payable to the US Department of State (DOS) may also be required, depending on the applicant.
[Back to reference] - Employers will be required to pay an additional $1 million, plus a $15,000 processing fee, for each dependent of the principal beneficiary under the Trump Corporate Gold Card program.
[Back to reference] - Only individuals who have never been subject to US tax on non-US income (e.g., US citizens, US green card holders, and individuals who exceeded the day count set under the substantial presence test), are eligible to apply for the Trump Platinum Card.
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