No. A private or estate-related expense is separate from the instructed government gift and processing charge.
Keep the transaction purposes distinct
The individual route currently requires US$15,000 nonrefundable processing and a US$1 million post-vetting gift. Identify the actual distribution and expenses rather than treating the gross estate value as the amount available to send.
The published framework describes a gift to the U.S. government together with a processing fee. The published programme amounts are in US dollars; review the actual currency transaction separately. Separate the Gold Card gift and processing charges from EB-5 investment capital, project costs and commercial risk. Clear pricing here means at least four separate lines: the processing fee per person, the gift per person, professional fees, and the filing costs of the immigrant classification actually used. A payment described for Gold Card purposes should be separated from legal fees, government filing fees for another category, and ordinary investment funds. Because the program uses EB-1 or EB-2 classification, eligibility and visa availability remain distinct from payment. Verify the official guidance before moving funds and do not count the gift as EB-5 invested capital. The typical accounting error is netting private employee development against a government obligation.