No. Use the actual official framework and identify family and continuing corporate obligations separately. The September 7, 2026 official processing fee is US$15,000 per person and nonrefundable; the principal gift is US$1,000,000 individually or US$2,000,000 per corporate-sponsored employee. Family and continuing corporate obligations are additional.
Budget by the real parties
A corporate gift is not an individual case simply because the applicant owns part of the business. Confirm the applicable amounts and conditions rather than substituting a preferred lower figure.
The Gold Card gift and processing charges should be kept separate from EB-5 investment capital, project costs, and commercial risk, since these are different kinds of financial arrangements rather than two prices for the identical outcome. Money paid to a private adviser sits under an engagement agreement with its own termination and refund clauses; a published government payment sits under published conditions, including a charge described as nonrefundable. The published initial processing fee is nonrefundable, while the gift is requested after successful vetting, and different charges carry different terms, so the nonrefundability of one establishes nothing about another.