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| Elizabeth M. Klarin |
According to the government’s website providing all information on who qualifies, where to apply and how to apply — trumpcard.gov — the price tag for individual applicants is a $15,000 initial processing fee, plus a $1-million “gift” upon completion of the individual’s vetting” as “evidence that the individual will substantially benefit the United States.” There may also be “small, additional fees” for immigrant visa issuance “depending on [the applicant’s] circumstances.”
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Which sounds, quite frankly, despite the price tag, like an incredible opportunity to obtain U.S. permanent residence without the usual hassle of proving qualifications based on historic criteria.
But there is that old adage: if something seems too good to be true, it probably is (or in this case, might be, so should be approached with a thorough understanding of risks). There are so many “maybes” and “what ifs” associated with this new immigrant visa opportunity that it is hard to determine the balance of risk versus reward.
For example, since President Donald Trump can’t unilaterally create a new visa category without the approval of Congress, the administration is using existing (available) visa categories and associated immigrant visa numbers to issue green cards under this new program. According to trumpcard.gov, “a successful applicant receives lawful permanent resident status as an EB-1 or EB-2 visa holder.” These are the first-preference (EB-1) and second-preference (EB-2) immigrant visa categories, historically and statutorily reserved for intending immigrants with extraordinary abilities in their field who are outstanding professors or researchers (EB-1); certain multinational managers and executives (EB-1); certain advanced degree professionals (EB-2); and/or immigrants with “exceptional” abilities in their field (EB-2) — not just a ton of disposable income. In the EB-2 second-preference category, qualified applicants normally have to go through a lengthy and rigorous labour certification process to qualify for permanent residence, unless they can also demonstrate that it would be in the national interest of the U.S. to allow them to skip this step.
For Trump Gold Card applicants, USCIS Form I-140G (required for application) gives applicants the option of choosing whether they want to be considered for the Gold Card based on extraordinary ability (EB-1) or exceptional ability working in a field in the national interest of the U.S. — without requiring them to demonstrate that they qualify under either category, to receive the benefit. The argument seems to be that their qualifying extraordinary ability is making and saving money, and that their donation itself is in the national interest of the U.S. But how and what option to choose to properly complete the form is not explained anywhere specifically. Normally, one would look to the detailed instructions on the form to determine which is the appropriate box to check; but the instructions for this form basically say, to paraphrase, “pick one.” Which has left many of even the most seasoned immigration practitioners scratching their heads and unable to confidently advise their clients on the surest path to success.
There is also the question of whether these Gold Cards will hold up over the long term. While the government website addresses some potential issues for holders, it is silent on others. It publicly recognizes that “the Trump Gold Card is a visa; therefore, national security and significant criminal risks are a basis for revocation.” However, it does not address whether future presidents will be able to revoke (or alter the terms of) these, since they are being issued under executive action rather than through formal congressional legislation. Programs established or codified by Congress are much harder for future presidents to unilaterally terminate; however, currently, there is no indication that President Trump is or will be seeking passage of legislation by Congress to codify the existing Gold Card program itself. There is simply and only an executive order underpinning all of it.
Despite the risks, there appears to be plenty of interest from people willing to take a chance on this fledgling program. According to Reuters, as of December 2025, about 10,000 people had preregistered for the Gold Card program immediately prior to its launch. In late December, after the launch, multiple major media news sources reported that at a private event, President Trump had claimed that the Gold Card program had already generated $1.3 billion in sales. No official numbers on revenue generation or the number of qualified applicants have been released to date.
If this works as publicized, it will be an incredibly swift and painless (except on the pocketbook) process to obtain U.S. permanent residence. The process is touted as only taking weeks “once an applicant’s processing fee and application are received,” although applicants may have to wait for an immigrant visa interview, with the time frame depending mostly on their country of nationality. As with any immigration process, additional documents might also be requested by the government, delaying the process further.
But wait — there’s more! The website also touts a future program, the “Trump Platinum Card,” which “will allow individual applicants to reside in the United States for up to 270 days per year without being subject to tax on non-U.S. income.” Predictably, the price tag for membership is higher than for the Gold Card — currently estimated but not confirmed to be $5 million — and specifications for how to apply and when this will become available have not yet been released.
It will be fascinating to see how this all plays out. Those considering participating in this program should carefully weigh the risks versus rewards and watch carefully for additional information from the government to clarify policy positions and adjudication trends, including approval rates and timelines as data emerges.
If you have questions regarding the content of this article or other immigration law topics, do not hesitate to reach out to Lippes Mathias immigration law team members, Elizabeth M. Klarin (eklarin@lippes.com) or Eileen M. Martin (emartin@lippes.com).
The opinions expressed are those of the author(s) and do not necessarily reflect the views of the author’s firm, its clients, LexisNexis Canada, Law360 Canada or any of its or their respective affiliates. This article is for general information purposes and is not intended to be and should not be taken as legal advice.
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