On September 19, 2025, President Donald Trump signed an executive order establishing the “Gold Card” program, which allows foreign nationals to obtain permanent residency in the United States with a minimum donation of $1 million (or $2 million via corporate sponsorship).
The order provides that these donations will be considered evidence of eligibility for extraordinary ability (EB-1) or national interest (EB-2 NIW) visa categories.
Furthermore, the program must be implemented within 90 days, with the departments of Commerce, State, and Homeland Security setting the operating rules.
Although the “Gold Card” promises a simplified path to residency, it does not eliminate existing restrictions, such as annual visa limits and eligibility requirements.
The “Platinum Card” (a donation of US$5 million) is also planned, with tax benefits on foreign income, although its details are still being studied.
What Brazilian investors should consider
- Making donations of this magnitude requires proven source of funds, due to the intense risk of compliance and audits.
- Even with the donation, the beneficiary will still be subject to global taxation in the US, unless the “Platinum Card” or legal modifications allow exceptions.
- Given the executive nature of the order, its legal basis may be challenged in court — its full implementation depends on subsequent regulations.
- Changing residence also requires asset, tax and corporate restructuring to avoid adverse effects in the country of origin.
How LTC Group can help:
LTC Group offers specialized consulting services to investors wishing to embrace this new path. Our support areas include:
- Asset and corporate structuring compatible with change of residence.
- International tax planning to mitigate tax impact in the US and Brazil.
- Due diligence and compliance assurance regarding the origin of resources.
- Legal support for registration, application and adaptation in accordance with future regulations.
In the current dynamic and uncertain scenario, having strategic and multi-jurisdictional advice is crucial.
Sources: https://www.whitehouse.gov/ https://www.fragomen.com / https://www.visalawyerblog.com / https://www.hubbis.com / https://www.saul.com
