No. The gift is a payment to the U.S. government with no enterprise, no return and no repayment, and the processing fee is stated as nonrefundable. EB-5 capital is at risk but may be returned if the enterprise succeeds; the two should never be entered in the same budget column.
One column for gifts, another for capital at risk
The financial difference between the two routes is not the headline amount but its character. Under EB-5 the couple would contribute capital to a new commercial enterprise, accept that it could be lost, and hope that after the conditional period and removal of conditions the enterprise returns it; the money is an investment with an uncertain outcome. Under the Gold Card framework the amounts stated on the official page are a nonrefundable processing fee per person and a gift per person to the U.S.
government; nothing is invested and nothing comes back. A budget that lists the gift beside the EB-5 capital as comparable outlays misstates the choice. The honest table has one column for money that is gone on payment and one for money at risk, with the EB-5 government fees and the Gold Card processing fees shown separately as costs in both.
The couple's accountant should also be asked how each treatment affects their Canadian tax position on the business-sale proceeds.