Registration Opens for Information on Trump Gold Card Residency Permit
As of June 12, 2025, individuals and businesses can register to receive information on the Trump Gold Card – a proposed alternative or possible replacement to the EB-5 visa, also known as the Immigrant Investor Visa. The Trump Card would offer permanent residency and a pathway to U.S. citizenship after five years for a fee of $5 million.
The Trump Card's position with respect to taxation is not entirely straightforward. A cardholder who moves to the U.S. would be a resident alien for purposes of U.S. taxation. U.S. residents are subject to taxes on worldwide income, encompassing earnings from both domestic and foreign sources. President Donald Trump has indicated in one speech that cardholders would be taxed solely on income earned within the U.S. and in another that "They won't have to pay tax from where they came."
However, that leaves a number of important details unanswered. The proposal will require anti-avoidance measures to prevent misuse of the exemption. There has been no mention of breaks for estate and gift taxes on non-U.S. assets. Also, Trump Card holders will remain liable for state and local taxes. Consequently, the Trump Card is unlikely to eliminate the need for pre-residence tax planning due to considerations related to various state and local income taxes, business taxes, and taxes on gifts and inheritances.
Congressional Hurdles
Though the administration is determined to press forward with the Trump Card, the program likely cannot be advanced without the approval of Congress. It is possible, even likely, that changes to immigration laws are necessary. Any changes regarding the taxation of individuals or businesses require amendments to the Internal Revenue Code (Code). Unless the Code provides for the special exemptions promised to Trump Card holders, they will likely be unable to receive preferential tax treatment. The One Big Beautiful Bill Act passed by the U.S. House of Representatives did not contain any reference to the Trump Card. However, the Senate amendment released on June 16, 2025, includes a Section 70205 entitled "Tax Treatment of Certain International Entrepreneurs," but the text is reserved.
Therefore, though it is possible to register an expression of interest and a request to be notified when the Trump Card is officially available, many questions and uncertainties remain regarding the program. The fact that Congress must amend the Code and likely the immigration laws to provide the promised preferential treatment means that there are many more steps to be taken before the program can be launched. Further, the Trump Card is unlikely to eliminate the need for tax planning for participants because of the need for careful review of both the terms of any proposed exemption and the continuing effect of state and local tax laws.
If you have any questions concerning the Trump Card, please contact the authors.
Holland & Knight Summer Associate Eric Chung also contributed to this alert.
Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.