No. The government gift should not simultaneously be treated as a retained personal living reserve or an investment expected to return capital.
Avoid counting the same money twice
The individual commitment currently includes US$15,000 nonrefundable processing and the post-vetting US$1 million gift. Budget housing, ordinary living costs and any additional official charges separately rather than assuming the gift will finance later personal expenses.
The current principal gift is US$1 million individually or US$2 million corporately after successful vetting and instructions. In EB-5 the money is capital invested in a new commercial enterprise, placed at risk, required to create at least ten qualifying full-time jobs, and capable in principle of being returned to the investor after conditions are removed. The gift is exactly that: money given to the government, not capital placed in a business, not a deposit and not an amount that returns on any outcome. The gift is not EB-5 capital or equity, and paying expenses does not guarantee approval, repayment or a completion date. Visa charges, medical expenses, translations, document procurement, tax advice, or private services may sit outside that sum.
Never describe that gift as EB-5 capital, because Gold Card is distinct from EB-5 investment and job requirements.