Trump's $5mn Gold Card in question as hefty price tag, tax burden may deter wealthy investors
'Worldwide taxation is the deal-breaker. Full stop,' Jeffrey Henseler, CEO of Passport Legacy Group, told Arabian Business in an interview. 'For many high-net-worth individuals, especially in the Gulf and Asia, the US is seen as a high-risk tax jurisdiction.'
The programme, announced by US President Donald Trump in May, would require applicants to make a non-refundable $5 million contribution to the US government—twenty times higher than some European alternatives that start at just $270,000 (€250,000).
Armand Arton, founder of Arton Capital and an advisor to governments on investment migration programmes, confirmed to Arabian Business that despite marketing buzz, the programme is nowhere near implementation.
'I can confirm that it's not yet [launched]. Nothing sold. There's no legislation which is drafted,' said Arton, who has been in contact with Republican senators working on the initiative. He expects more details after meetings with US officials next week.
The ' Gold Card ' scheme would require applicants to make a non-refundable contribution unlike the existing EB-5 visa programme, which requires a $1 million investment in job-creating ventures. The Gold Card payment would help 'replace and cancel debt of the government,' according to Arton.
However, the programme faces steep competition from established European alternatives.
Tax issues, European competition
'The most important question is, are you going to become taxable on worldwide income as a permanent resident of the United States?' Arton said. 'The tax exemption must be there.'
European residency programmes offer significant advantages, starting at investment levels as low as $270,000 (€250,000) compared to the $5 million donation required for the Gold Card, Arton noted.
He highlighted Italy's programme as particularly competitive, offering a flat tax rate of $216,000 (€200,000) per year for 15 years regardless of worldwide income.
'Even if you take that 15 years of $216,000, that's $3.24 million,' Arton explained. 'People will prefer to say that they're paying $3.24 million over 15 years and they're not taxed for 15 years and have access to a European lifestyle, than paying $5 million to get access only to the US and then being taxable on worldwide income.'
Henseler echoed these concerns about the price differential in a separate interview with Arabian Business.
'The US is requesting an investment 20 times bigger than what we know from the EU,' Henseler said. 'A $270,000 (€250,000) investment for a European residency gives access to the EU lifestyle, business climate, and family benefits. Compare that to a $5 million non-refundable contribution – not even an investment – and it becomes clear that this programme is targeting a very specific niche.'
Both experts identified worldwide taxation as potentially the most significant obstacle to the programme's success.
'Worldwide taxation is the deal-breaker. Full stop,' Henseler said. 'For many high-net-worth individuals, especially in the Gulf and Asia, the US is seen as a high-risk tax jurisdiction. FATCA compliance, global asset disclosure, and aggressive IRS enforcement don't sit well with families trying to diversify or protect generational wealth.'
According to Henseler, the programme would need to 'avoid automatic tax residency' and 'limit or remove global reporting requirements' to be competitive.
Ultra-wealthy appeal
According to Arton, only individuals with a net worth exceeding $100 million would likely consider the programme, as the $5 million contribution would represent 5 per cent of their personal wealth.
'I don't believe that people with 30 million, 40 million and 50 million will risk, not risk, but will kind of lose 10 to 20 per cent of their personal network just to go to America,' he said.
Interest has primarily come from ultra-high-net-worth individuals in Asia, particularly Singapore, India, Indonesia, and Malaysia, many of whom already have investments in the US or children studying at American universities.
'We have received interest from 70 millionaires,' Arton said, referring to individuals worth more than $100 million. These potential applicants are mainly 'Southeast Asian wealthy families that have kids in the US, have already some investments in the US.'
Middle Eastern families with political connections might also apply 'just to please' Trump, Arton suggested.
Programme status remains unclear
Despite reports that cards have already been sold, Arton, who is in contact with Republican senators working on the legislation, confirmed that the programme has not yet launched and no cards have been issued.
'I can confirm that it's not yet [launched]. Nothing sold. There's no legislation which is drafted,' he said, adding that he expects more information in the coming months.
The proposed Gold Card would offer permanent residency rights, similar to a Green Card, with a streamlined six-month application process compared to the years-long waits under the EB-5 programme.
However, the path to citizenship remains unclear, including whether physical presence requirements would be waived.
Both experts noted the apparent contradiction in right-wing immigration policies.
'It's a very interesting rhetoric that extreme right politicians are going that way—anti-migration, but at the same time very open to the idea of wealthy migrants coming and helping their economic agenda,' Arton said.
Henseler offered a similar assessment: 'The right wing wants to attract the wealthy, the left wing wants to attract the poor. Right-wing governments are pragmatic when it comes to capital inflow. They understand that billionaires don't take jobs; they create them.'
Gold Card vs. European RBIs
According to a comparative analysis of investment migration programmes, the Gold Card faces several structural disadvantages beyond just price.
European residency-by-investment programmes start at approximately $270,000 (€250,000) in Greece and around $540,000 (€500,000) in Portugal and Spain, compared to the $5 million non-refundable contribution proposed for the Gold Card.
Global taxation represents another significant difference. European programmes typically don't trigger automatic worldwide taxation unless applicants stay more than 183 days per year in the country. By contrast, US permanent residents face taxation on their worldwide income regardless of physical presence.
Annual stay requirements also differ dramatically. While some European programmes require as little as zero to seven days per year of physical presence, US residency status typically requires substantial time in-country or risks being lost.
Exit options present another contrast. European programmes generally allow investors to easily drop or switch programmes, while the US imposes an exit tax for high-net-worth individuals renouncing residency.
Privacy and reporting requirements also differ substantially. European jurisdictions offer varying levels of confidentiality, while the US system requires extensive financial disclosures through FBAR and FATCA compliance.
The comparison highlights what Henseler describes as the 'deal-breaker' of worldwide taxation. European programmes like Italy's offer optional flat tax regimes ($108,000 or €100,000 per year) on global income, while the US system offers no such exemptions and requires extensive reporting.
Despite the competitive challenges, Arton believes the Gold Card is 'great news for the industry' of investment migration, as it represents a major endorsement from 'the biggest economy in the world.'
The comments came amid a global boom in residency and citizenship by investment programmes, which Arton says is growing at approximately 20 per cent annually. He attributes this growth to political uncertainty, the COVID-19 pandemic, and geopolitical conflicts like the Russia-Ukraine war, which have prompted wealthy individuals to seek 'Plan B' residency options.
'The demand is always increasing by 20 per cent every year,' Arton said. 'I don't see that slowing down anytime soon.'
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