• Insights

E-2 Treaty Investor Visas - Does Yours Pass the "Smell Test"?

December 13, 2016

insight-blog-default

Country / Territory

  • United StatesUnited States

Related contacts

Porthole Headshot Image of Fragomen [Irvine][Associate][JennaRobinson]

Jenna Robinson

Senior Associate

Irvine, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Atlanta
  • Boston
  • Chicago
  • Fragomen in Miami, FL
  • Dallas
  • Houston
  • Irvine
  • Los Angeles
  • New York
  • Phoenix
  • San Diego
  • San Francisco
  • San José
  • Silicon Valley
  • Detroit
  • Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Porthole Headshot Image of Fragomen [Irvine][Associate][JennaRobinson]

Jenna Robinson

Senior Associate

Irvine, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Atlanta
  • Boston
  • Chicago
  • Fragomen in Miami, FL
  • Dallas
  • Houston
  • Irvine
  • Los Angeles
  • New York
  • Phoenix
  • San Diego
  • San Francisco
  • San José
  • Silicon Valley
  • Detroit
  • Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Porthole Headshot Image of Fragomen [Irvine][Associate][JennaRobinson]

Jenna Robinson

Senior Associate

Irvine, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Atlanta
  • Boston
  • Chicago
  • Fragomen in Miami, FL
  • Dallas
  • Houston
  • Irvine
  • Los Angeles
  • New York
  • Phoenix
  • San Diego
  • San Francisco
  • San José
  • Silicon Valley
  • Detroit
  • Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Jenna Robinson

The U.S. has entered into treaties with several countries and established the E-2 visa to allow businesspeople from these countries to work for a business in which they have invested. The E-2 treaty investor visa has become an increasingly popular path for immigrants looking to work in the U.S. According to a report issued by the Department of State, the number of foreign workers obtaining this visa has steadily increased by more than 37% between 2011 (39,997) and 2015 (59,221).

Investment: The central focal point of E-2 visa

While most of the requirements for an E-2 are relatively self-explanatory, the central focal point is usually the investment. In contrast to the heavily-publicized EB-5 program, the E-2 has no set investment number, rather, it requires a “substantial investment,” which is open to wide interpretation. Most immigration lawyers suggest a threshold of $100,000 to be generally acceptable, but this number doesn’t always make sense for all businesses.

I recently attended an AILA (American Immigration Lawyers Association) event where a former Department of State Consular Officer provided some valuable insight on the E-2 visa. Though it’s important to meet the plain language of the requirements, the former officer promoted divergent thinking when advising clients on these applications and stressed the fact that each application is judged by a totality of the circumstances test.

Let’s discuss a few hypotheticals to put this into perspective. Imaginary Ian, a 22-year-old business major on an F-1 student visa, incorporates a business that allows amateurs and avid sports fans to easily organize and manage sporting activities through a user-friendly, one-stop mobile and web solution to schedule pick-up games or tournaments. He received a $50,000 cash gift from his parents, which he invested into the company, but is operating the business out of his home. His company doesn’t employ anyone yet, but he has provided an extensive business plan with 5-year projections showing significant income within the first 5 years, mostly indirect employment of independent contractors to maintain sites, conduct sales, etc. While there may be a few challenges with his petition, overall, imaginary Ian has a good shot at an approval. His investment is lower than the advisable $100,000, but because of the nature of the business he has proposed, a larger investment is not entirely necessary.

The software platform he has developed has already been beta-tested on numerous campuses and his business is as close to fully-operational as possible. The most identifiable issue with his case is the proposed use of his home as an office. Although we are in the 21st century and businesses are increasingly operating remotely through virtual offices, Consular Officers and Immigration still view this as an unfavorable set up.

As a best practice, I still advise all of my clients to set up a brick and mortar location with companies such as Regus or WeWork. This is a much cheaper and convenient option in comparison to traditional leasing methods.

Another example involves a 70-year-old woman, Stranger Sue, who decides she wants to buy a nail salon. She invests $125,000 to get the place up and running, hires 8-10 employees, including two managers who will be responsible for operating the business, and buys a beach-front home 50 miles away from the salon. Her investment is substantial and not marginal, she has hired U.S. workers, and the nail salon is a real and operating commercial enterprise. However, when viewing her case through the totality of the circumstances, Stranger Sue likely has no intent to direct and develop the enterprise. Not only has she settled 50 miles away, she has hired individuals to actively manage the business on her behalf. The E-2 should not be used as a path to retirement; the investor must actively direct and develop the business on a regular basis.

Deciding the fate of an E-2 case

As can be seen with these two examples, deciding the fate of an E-2 case is a balancing act. For the best results, it is important to look at the application from the Officer’s perspective. Does it make sense; does it pass the “smell test”? If you have any doubts, you can bet the Officer will too. For more information on how to best strategize your E-2 application, please contact me at [email protected]

Country / Territory

  • United StatesUnited States

Related contacts

Porthole Headshot Image of Fragomen [Irvine][Associate][JennaRobinson]

Jenna Robinson

Senior Associate

Irvine, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Atlanta
  • Boston
  • Chicago
  • Fragomen in Miami, FL
  • Dallas
  • Houston
  • Irvine
  • Los Angeles
  • New York
  • Phoenix
  • San Diego
  • San Francisco
  • San José
  • Silicon Valley
  • Detroit
  • Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Porthole Headshot Image of Fragomen [Irvine][Associate][JennaRobinson]

Jenna Robinson

Senior Associate

Irvine, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Atlanta
  • Boston
  • Chicago
  • Fragomen in Miami, FL
  • Dallas
  • Houston
  • Irvine
  • Los Angeles
  • New York
  • Phoenix
  • San Diego
  • San Francisco
  • San José
  • Silicon Valley
  • Detroit
  • Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Porthole Headshot Image of Fragomen [Irvine][Associate][JennaRobinson]

Jenna Robinson

Senior Associate

Irvine, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Atlanta
  • Boston
  • Chicago
  • Fragomen in Miami, FL
  • Dallas
  • Houston
  • Irvine
  • Los Angeles
  • New York
  • Phoenix
  • San Diego
  • San Francisco
  • San José
  • Silicon Valley
  • Detroit
  • Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Fragomen news

Fragomen Appoints Timo Heck as Managing Partner of DACH Region

Fragomen has appointed Timo Heck as Managing Partner of the DACH region, encompassing Germany, Austria and Switzerland.

Learn more

Awards

Fragomen Professionals Recognized in the 2027 Edition of The Best Lawyers in Mexico™

Eight professionals in Fragomen’s Mexico City office have been recognized in the 2027 edition of The Best Lawyers in Mexico™ for Immigration Law.

Learn more

Blog post

How Employers Can Support Integration and Retain International Talent in Germany

Senior Manager Katharina Vorländer explores how employers in Germany can look beyond the initial immigration process to support integration, long-term stability and the retention of international talent.

Learn more

Media mentions

Scottish Legal News: Scotland’s Investment Ambitions Depend on Workforce Readiness

Director Kelly Hardman explores why workforce planning is essential to Scotland’s investment ambitions and long-term economic growth.

Learn more

Fragomen news

Comment on DHS Proposal to Eliminate the 60-day Grace PeriodLearn more

Fragomen news

Comment on DHS proposal to impose up to $100,000 in Optional Practical Training FeesLearn more

Media mentions

Human Resources Director: Fixed-Term Contract Limits Squeeze Visa Sponsorship, Research Warns

Co-authors Partner Charles Johanes, Senior Counsel Anna Boucher and Allens Partner Tarsha Gavin explore the intersection of Australia’s migration and employment laws and the implications for employers sponsoring temporary visa holders.

Learn more

Media mentions

Prawo: Pracodawca na pierwszej linii: jak reforma zatrudniania cudzoziemców przesuwa odpowiedzialność na firmy

Partner Karolina Schiffter examines how Poland’s proposed foreign employment reforms could increase employers’ administrative and compliance responsibilities.

Learn more

Blog post

Trusted Digital Identity Is Critical Infrastructure for Global Mobility

In the first blog in a new series, Managing Director, Digital Identity Amit Sharma explores why trusted digital identity is becoming increasingly important to global mobility, how reusable digital credentials could work and why interoperability across systems and jurisdictions will be critical.

Learn more

Blog post

UK Global Talent Visa vs Innovator Founder Visa: A Guide for Tech Professionals, Researchers and Founders

Senior Associate Amelia Haynes compares the UK’s Global Talent and Innovator Founder visa routes, examining who each route may suit, the evidence required, professional flexibility and potential pathways to settlement.

Learn more

Blog post

Polish Citizenship by Descent: Finding Family Records and Navigating Polish Archives

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain how applicants pursuing Polish citizenship by descent can locate family records, navigate archives and obtain documentary evidence that can be used in citizenship proceedings.

Learn more
Generic Insights

Fragomen news

2026年10月 米国移民法ダイジェストLearn more

Fragomen news

Fragomen Appoints Timo Heck as Managing Partner of DACH Region

Fragomen has appointed Timo Heck as Managing Partner of the DACH region, encompassing Germany, Austria and Switzerland.

Learn more

Awards

Fragomen Professionals Recognized in the 2027 Edition of The Best Lawyers in Mexico™

Eight professionals in Fragomen’s Mexico City office have been recognized in the 2027 edition of The Best Lawyers in Mexico™ for Immigration Law.

Learn more

Blog post

How Employers Can Support Integration and Retain International Talent in Germany

Senior Manager Katharina Vorländer explores how employers in Germany can look beyond the initial immigration process to support integration, long-term stability and the retention of international talent.

Learn more

Media mentions

Scottish Legal News: Scotland’s Investment Ambitions Depend on Workforce Readiness

Director Kelly Hardman explores why workforce planning is essential to Scotland’s investment ambitions and long-term economic growth.

Learn more

Fragomen news

Comment on DHS Proposal to Eliminate the 60-day Grace PeriodLearn more

Fragomen news

Comment on DHS proposal to impose up to $100,000 in Optional Practical Training FeesLearn more

Media mentions

Human Resources Director: Fixed-Term Contract Limits Squeeze Visa Sponsorship, Research Warns

Co-authors Partner Charles Johanes, Senior Counsel Anna Boucher and Allens Partner Tarsha Gavin explore the intersection of Australia’s migration and employment laws and the implications for employers sponsoring temporary visa holders.

Learn more

Media mentions

Prawo: Pracodawca na pierwszej linii: jak reforma zatrudniania cudzoziemców przesuwa odpowiedzialność na firmy

Partner Karolina Schiffter examines how Poland’s proposed foreign employment reforms could increase employers’ administrative and compliance responsibilities.

Learn more

Blog post

Trusted Digital Identity Is Critical Infrastructure for Global Mobility

In the first blog in a new series, Managing Director, Digital Identity Amit Sharma explores why trusted digital identity is becoming increasingly important to global mobility, how reusable digital credentials could work and why interoperability across systems and jurisdictions will be critical.

Learn more

Blog post

UK Global Talent Visa vs Innovator Founder Visa: A Guide for Tech Professionals, Researchers and Founders

Senior Associate Amelia Haynes compares the UK’s Global Talent and Innovator Founder visa routes, examining who each route may suit, the evidence required, professional flexibility and potential pathways to settlement.

Learn more

Blog post

Polish Citizenship by Descent: Finding Family Records and Navigating Polish Archives

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain how applicants pursuing Polish citizenship by descent can locate family records, navigate archives and obtain documentary evidence that can be used in citizenship proceedings.

Learn more
Generic Insights

Fragomen news

2026年10月 米国移民法ダイジェストLearn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
November 12, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
November 12, 2026 | Austria, Germany, SwitzerlandFragomen Appoints Timo Heck as Managing Partner of DACH Region
November 12, 2026 | MexicoFragomen Professionals Recognized in the 2027 Edition of The Best Lawyers in Mexico™
November 12, 2026 | IndiaIndia: Simplification of Visa Categories and Reduction in Application Information Requirements
November 12, 2026 | IrelandIreland: New Seasonal Employment Permit Program Launched for Horticultural Sector Workers
November 12, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
November 12, 2026 | Austria, Germany, SwitzerlandFragomen Appoints Timo Heck as Managing Partner of DACH Region
November 12, 2026 | MexicoFragomen Professionals Recognized in the 2027 Edition of The Best Lawyers in Mexico™
November 12, 2026 | IndiaIndia: Simplification of Visa Categories and Reduction in Application Information Requirements
November 12, 2026 | IrelandIreland: New Seasonal Employment Permit Program Launched for Horticultural Sector Workers
November 12, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.