No. It is a gift to the Department of Commerce for deposit in a separate U.S. Treasury fund and is not returned, does not generate a return and is not an equity interest; the processing fee is also described as nonrefundable.
Enter it as an expense, not as an investment
Hypothetical example: A Portugal Cove-St. Philip's applicant preparing a household balance sheet should record the gift and the processing fee as outflows with no corresponding asset. Under the official terms as read on September 7, 2026, the processing fee is US$15,000 per person and nonrefundable, the individual gift is US$1,000,000 and the corporate gift is US$2,000,000, with additional fees and gifts for each joining family member and continuing corporate charges where a company sponsors. None of it is exchanged for shares, a loan or a claim against anyone. That distinguishes it fundamentally from EB-5, where the capital is at risk in an enterprise but remains the investor's investment and may be returned when the investment concludes, and from E-2, where the funds buy a business the investor owns. Government fees for the underlying immigrant petition and visa are additional. Anyone describing the gift as recoverable, refundable or yield-bearing is describing something other than the official framework.
Hypothetical example: a freight-broker owner is told that a company may contribute toward a Gold Card amount. The applicant must first determine from the official framework who makes the payment, who bears the processing charge, and whether any employer arrangement creates separate tax or employment questions. A bank confirmation and the government's payment instruction settle whether the required payment has actually been made. Do not characterize the amount as capital in a recoverable enterprise: the framework describes a payment by the applicant to the U.S. government, and it is not a conventional visa.