I haven’t confirmed with the IRS or a tax lawyer, but the IRS publication 590A (page 33-34) states the following about Exempt Transactions:
The following two types of transactions aren’t prohibited transactions if they meet the requirements that follow.
• Payments of cash, property, or other consideration by the sponsor of your traditional IRA to you (or members of your family).
Chapter 1 Traditional IRAs
• Your receipt of services at reduced or no cost from the bank where your traditional IRA is established or maintained.
Payments of cash, property, or other consideration. Even if a sponsor makes payments to you or your family, there is no prohibited transaction if all three of the following requirements are met.
- The payments are for establishing a traditional IRA or for making additional contributions to it.
- The IRA is established solely to benefit you, your spouse, and your or your spouse’s beneficiaries.
- During the year, the total fair market value of the pay-ments you receive isn’t more than:
a. $10 for IRA deposits of less than $5,000, or
b. $20 for IRA deposits of $5,000 or more. If the consideration is group term life insurance, requirements (1) and (3) don’t apply if no more than $5,000 of the face value of the insurance is based on a dollar-for-dollar basis on the assets in your IRA.
Services received at reduced or no cost. Even if a sponsor provides services at reduced or no cost, there is no prohibited transaction if all of the following requirements are met.
• The traditional IRA qualifying you to receive the services is established and maintained for the benefit of you, your spouse, and your or your spouse’s beneficiaries.
• The bank itself can legally offer the services.
• The services are provided in the ordinary course of business by the bank (or a bank affiliate) to customers who qualify but don’t maintain an IRA (or a Keogh plan).
• The determination, for a traditional IRA, of who qualifies for these services is based on an IRA (or a Keogh plan) deposit balance equal to the lowest qualifying balance for any other type of account.
• The rate of return on a traditional IRA investment that qualifies isn’t less than the return on an identical investment that could have been made at the same time at the same branch of the bank by a customer who isn’t eligible for (or doesn’t receive) these services.
So, if the bank that holds your funds is allowed to give benefits to the IRA holder as long as those benefits are the same for non-IRA funds, it should follow that the Golden Visa application should get the same treatment? A person is eligible for the Golden Visa whether or not the funds are from an IRA or from a non-IRA source.