Treat capital already transferred into the EB-5 investment as money currently at risk under that investment's own terms, and compare the cost and risk of continuing to hold it there against the Gold Card's fee and gift terms, rather than treating the EB-5 amount as a sunk cost that no longer matters.
Compare current risk exposure, not just headline totals
Ask the fund administrator or counsel what the realistic range of outcomes is for the EB-5 capital if it remains invested, and separately confirm the current official Gold Card fee schedule for the whole household. A large amount already committed to EB-5 is still an active financial exposure, not a cost that has already been resolved.
Separate committed EB-5 capital, potential recovery, project duties, and future advice costs; do not call the investment a sunk fee. Under current official instructions, Gold Card starts online with the US$15,000 nonrefundable DHS processing fee. After payment settles, USCIS prompts Form I-140G; vetting follows, and upon successful vetting officials request the US$1 million federal gift. That gift purchases no project interest. Each included spouse or unmarried child under 21 is subject to an additional US$15,000 DHS processing fee and US$1 million gift. Gold Card currently uses EB-1 or EB-2 classification, not EB-5; the executive order only directs officials to consider a possible future expansion involving EB-5. Recheck the official process before directing any payment. The usual mistake is comparing liquidity using optimistic redemption assumptions.
Hypothetical example: a Clarence-Rockland veterinary-pharmaceutical distributor has capital tied to an EB-5 enterprise whose agreement permits repayment only under specified conditions. The applicant requests written status and asks counsel whether withdrawal could impair the case or cause commercial loss. A household spreadsheet assigns no value to unconfirmed recovery and places the Gold Card fee and gift on their proper procedural dates. This reveals the maximum overlapping cash exposure without pretending that either route guarantees approval or that EB-5 funds can be credited toward the federal gift.