As a payment with no return, not as an asset. EB-5 capital is an at-risk investment in a business; the Gold Card gift is a payment to the U.S. government with no enterprise, no jobs test and no repayment.
Do not put a gift on the balance sheet as an investment
The two routes look comparable only because both involve a large sum and both connect to permanent residence. In substance they are opposites. An EB-5 investor places capital into a new commercial enterprise, must show it created ten full-time jobs, bears the risk of loss and may, depending on the project, receive the capital back.
A Gold Card payer makes a nonrefundable processing fee and then a gift to the U.S. government; nothing is invested, nothing is returned and no business is required. The company's accountant should record the fee and the gift as the tax adviser directs, never as an investment or a receivable from the employee unless the agreement genuinely makes it a loan.
Corporate cases additionally carry the annual maintenance charge and a transfer charge on reassignment, as the official terms describe. Budget those as recurring costs. Any board comparison with EB-5 should compare obligations and risks, not prices, and be re-run against the official page on the day of decision.