On September 19, 2025, President Trump signed an executive order formalizing the Gold Card as a new immigration path to residency in the United States.

Per the order:

  • To qualify for a Gold Card, a foreign individual must make an unrestricted gift of $1 million to the US Department of Commerce.
  • The amount increases to $2 million if a corporation or similar business entity donates on the individual’s behalf.

The order instructs the Secretaries of State and Homeland Security to treat the gift as evidence of:

  • Exceptional business ability and national benefit under 8 U.S.C. 1153(b)(2)(A), and
  • Eligibility for a national-interest waiver under 8 U.S.C. 1153(b)(2)(B), and thereby
  • Eligibility for priority workers and employment-based immigrants under 8 U.S.C. 1153(b)(1)(A).

The order gives the relevant agencies 90 days, until December 18, 2025, to implement the Gold Card program.

Is the Platinum Card next?

A special government website, which has been active for some time, provides information on the Gold Card and contains content indicating that the site may be used to accept Gold Card applications.

In addition, it refers to a “Platinum Card” that was not listed in the September 19, 2025, executive order:

“Sign up now and secure your place on the waiting list for the Trump Platinum Card. For a processing fee and, after DHS vetting, a $5 million contribution, you will have the ability to spend up to 270 days in the United States without being subject to U.S. taxes on non-U.S. income.”

The information is active on the site, suggesting that another executive order may be coming soon.

What are the tax implications of the Gold Card and Platinum Card?

There are many unknowns about how the Gold Card will work from a tax perspective, and the Platinum Card raises additional questions. In the executive order, Section 3 provides some details on Gold Card implementation from an immigration perspective but no details related to tax.

Before the One Big Beautiful Bill Act (OB3) was passed on July 4, 2025, the Senate’s version of the tax bill included a special new provision called, “Tax treatment of certain international entrepreneurs.”

This may have been the Gold Card tax provisions; however, it did not contain any specific details and was dropped at the last moment.

So, open questions abound.

Specifically, will the tax laws and reporting requirements that apply to other US tax residents also apply to Gold Card holders? Little is known on the following questions:

  1. Will Gold Card holders be taxable on their worldwide income (like Green Card holders, US citizens, and other US tax residents)?
  2. Will Gold Card holders be subject to worldwide international informational reporting requirements, designed to reduce tax evasion (like Green Card holders, US citizens, and other US tax residents)?
  3. Will legislators need to amend IRC 7701(b)(1)(A) (i.e., the tax code section detailing US tax residency for Green Card holders and individuals who qualify for residency under the Substantial Presence Test) to add in Gold Card holders?

Likewise, few details are available related to the Platinum Card and its potential holders:

  1. Will there be an executive order for the Platinum Card?
  2. Will there be an amendment to US tax residency rules under IRC 7701(b)(1)(B) to create a “Non-Domiciled Tax Regime” for Platinum Card holders that would in effect make them nonresident aliens for tax purposes for a certain period of time, i.e., the 270 days indicated on the special website?
  3. What happens if a Platinum Card holder violates the 270-day test?
  4. Will Platinum Card holders be subject to worldwide international informational reporting requirements (like Green Card holders, US citizens, and other US tax residents)?

What’s next?

Congress may vote on a second reconciliation tax bill, which some are calling “Too Big Too Beautiful,” before the end of 2025. This second bill will likely need to add provisions for the Gold Card and potentially even for the Platinum Card.

As more details unfold and answers to these questions become clear, The Wolf Group will continue to monitor and provide guidance.

 

The Wolf Group has been providing specialized international tax advice to Green Card holders, US tax residents, foreign nationals holding many different US visa types, and other individuals with cross-border tax needs since 1983. If you have questions related to the US tax treatment for your specific immigration situation, please contact us.