No. Conditional residence begins at immigrant admission or adjustment approval, and age protection requires the applicable individual analysis. The gift date is a financial event.
Keep the relevant clocks separate
Record the actual immigration dates and visa availability for any CSPA question. The ordinary I-829 window is the 90 days before the second anniversary of conditional residence, not the transfer anniversary.
The process generally involves an investor petition, an immigrant visa or adjustment-of-status stage where available, and later removal of conditions tied to evidence that the required jobs were actually created (or, for a troubled business, preserved) and sustained. Check current USCIS processing time data for the relevant EB-5 petition type and the visa bulletin for the applicable category and country of chargeability, and revisit both periodically rather than relying on a one-time estimate, since both can change materially over a multi-year case. Escrow and administrative charges, subscription fees, legal work on the petition, translations of financial records spanning several countries, medical examinations, and the consular or adjustment steps for each family member all fall at different points.