Trump Administration Unveils the “Gold Card” Visa Program

• The contribution will take the form of a “significant financial gift” to the U.S. Treasury: $1 million for an individual, and $2 million for companies donating on behalf of an individual.
• Individuals will donate the requisite amount after paying a non-refundable processing fee and receiving a positive visa adjudication from the Department of Homeland Security.
• Applicants must already be eligible for lawful permanent resident status, and the visa is revokable in the case of national security risks, among other reasons.
• The new program would serve as means to satisfy the “exceptional ability” requirements of the current EB-1 and EB-2 visa pathways for aliens with extraordinary or exceptional ability.

Some 80,000 Trump Gold Cards will be made available, according to U.S. Commerce Secretary Howard Lutnick. Additional guidance is expected, as the EO also ordered the Secretary of Commerce, the Secretary of State and the Secretary of Homeland Security to take all necessary and appropriate steps to implement the Gold Card within 90 days of the order.

For federal tax purposes, the official Trump Gold Card website states that Gold Card holders “will be treated similarly to other permanent residents and citizens.” U.S. permanent residents and citizens are currently subject to U.S. taxes and reporting on their worldwide income. This means that U.S. permanent residents and citizens have to pay federal income taxes on income earned outside the United States. The Administration did, however, also hint at a Platinum Card for a $5 million financial contribution that would “allow individual applications to reside in the United States for up to 270 days per year without being subject to tax on non-U.S. income.” Such a program would give these Platinum Card recipients a substantive tax advantage that is not available to U.S. citizens and permanent residents, as these Platinum Card recipients would be able to spend a majority of their time in the United States without being subject to income taxes on their foreign income. This program is not yet available but is reportedly in the works; Lutnick suggested that the program would need congressional approval before they could formally launch the $5 million-per-applicant program. Key questions regarding this Platinum program remain, including whether Platinum Card holders would be subject to or exempt from U.S. estate and gift taxes.

If a Platinum Card program is ultimately introduced, it could create significant tax planning and residency planning opportunities for foreign high-net-worth individuals. The program would effectively eliminate the substantial physical presence rules for these holders, by allowing them to spend up to 270 days per year in the United States without being subject to U.S. federal taxation on their worldwide income. Such a rule would also be a departure from the current U.S. federal tax laws which imposes a worldwide income tax on U.S. citizens and residents. Thus, the program could attract foreign individuals who might otherwise avoid the United States due to its aggressive tax reach.

This new action coincided with another major change in immigration policy. After signing the Gold Card order, the President also signed Executive Proclamation 10973, Restrictions on Entry of Certain Nonimmigrant Workers. The proclamation targets petitioners using the H1-B program for specialty occupation workers. Effective as of September 21, 2025, new petitioners will be denied entry into the United States “unless their petition is accompanied by a $100,000 payment,” according to the White House’s fact sheet on the proclamation. The proclamation adds that the restriction will expire in 12 months if the President decides not to extend it.

The Gold Card and potential Platinum Card programs present novel opportunities and risks for investors, corporations and high-net-worth individuals. At the same time, the new H-1B restrictions underscore the Administration’s willingness to reshape traditional employment-based immigration categories through financial barriers. Stakeholders should closely monitor forthcoming agency guidance, assess tax implications, and prepare for both the opportunities and challenges these policies present as additional information becomes available. Proactive planning will be essential as the landscape of U.S. immigration and taxation continues to evolve.

(The authors thank Pillsbury’s Trade and Policy Specialist Xavier Gillett for his assistance with the article.)