No. Inclusion turns on being a legally married spouse, not on holding shares. Her shareholding matters to the funds analysis, not to derivative eligibility. If she joins, she adds US$15,000 plus a US$1,000,000 gift when instructed. Her own eligibility and admissibility must still support inclusion; existing United States status is not required simply to apply from abroad.
Deciding at the outset in a two-shareholder household
Suppose the couple also has an unmarried 19-year-old daughter who could be included as a child under 21. Including family from the start is officially recommended for programme benefits; adding someone later is not impossible, but it is not free either, since the same per-person amounts apply. That decision is not purely a household preference: each person needs a qualifying relationship and individual eligibility.
A spouse and each unmarried child under twenty-one, and each of them carries a further nonrefundable processing fee and a further US$1 million gift. The FAQ recommends initially including the intended eligible joining spouse and unmarried children under 21. Vetting precedes the program’s requested US$1 million gift for every included relative. Do not assume derivative rules borrowed from other categories apply.