Not in the same column. The gift is a payment to the U.S. government that is not placed in any enterprise and does not return; EB-5 capital is placed at risk in a business that may repay it. Comparing the headline figures alone misstates the choice.
Irrecoverable payment and capital at risk are different things
A budget can compare two routes only if it preserves what each payment is. Under EB-5 the applicant contributes qualifying capital to a new commercial enterprise, accepts that it may be lost, and may see it returned if the enterprise succeeds and the applicable sustainment requirements have been met. Under the Gold Card framework the applicant pays a nonrefundable processing fee and makes a gift after successful vetting; there is no investor enterprise, ten-job obligation or capital return.
Government and professional fees should be listed separately. Evidence about the shop or payment source should be supplied if required by the current official instructions, not presented as a general Gold Card source-of-funds rule that the published page does not state.