Important Updates
Important Updates
April 21, 2026 | NetherlandsThe Sunday Times: How to Make Your Move from the UK to the Netherlands
April 23, 2026 | United Kingdom, United StatesCitywealth Leaders List: Top 30 Immigration Advisors 2026 Recognises Four Fragomen Professionals
April 22, 2026 | European UnionEuropean Union/Schengen Area: Internal Schengen Border Checks Situation
April 22, 2026 | Saudi ArabiaSaudi Arabia: Nitaqat Calculation Now Requires Online Contract Submission
April 21, 2026 | Russia, Saudi ArabiaRussia/Saudi Arabia: Mutual Visa-Free Entry Forthcoming
April 21, 2026 | NetherlandsThe Sunday Times: How to Make Your Move from the UK to the Netherlands
April 23, 2026 | United Kingdom, United StatesCitywealth Leaders List: Top 30 Immigration Advisors 2026 Recognises Four Fragomen Professionals
April 22, 2026 | European UnionEuropean Union/Schengen Area: Internal Schengen Border Checks Situation
April 22, 2026 | Saudi ArabiaSaudi Arabia: Nitaqat Calculation Now Requires Online Contract Submission
April 21, 2026 | Russia, Saudi ArabiaRussia/Saudi Arabia: Mutual Visa-Free Entry Forthcoming
April 21, 2026 | NetherlandsThe Sunday Times: How to Make Your Move from the UK to the Netherlands
Subscribe
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 InsightsVietnamese ImmigrationView 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
  • Vietnamese Immigration
  • 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
  • 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

Fragomen in Irvine, CA, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Fragomen in Atlanta, GA
  • Fragomen in Boston, MA
  • Fragomen in Chicago, IL
  • Fragomen in Miami, FL
  • Fragomen in Dallas, TX
  • Fragomen in Houston, TX
  • Fragomen in Irvine, CA
  • Fragomen in Los Angeles, CA
  • Fragomen in New York, NY
  • Fragomen in Phoenix, AZ
  • Fragomen in San Diego, CA
  • Fragomen in San Francisco, CA
  • Fragomen in San José, Costa Rica
  • Fragomen in Silicon Valley, CA
  • Fragomen in Detroit, MI
  • Fragomen in Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

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

Jenna Robinson

Senior Associate

Fragomen in Irvine, CA, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Fragomen in Atlanta, GA
  • Fragomen in Boston, MA
  • Fragomen in Chicago, IL
  • Fragomen in Miami, FL
  • Fragomen in Dallas, TX
  • Fragomen in Houston, TX
  • Fragomen in Irvine, CA
  • Fragomen in Los Angeles, CA
  • Fragomen in New York, NY
  • Fragomen in Phoenix, AZ
  • Fragomen in San Diego, CA
  • Fragomen in San Francisco, CA
  • Fragomen in San José, Costa Rica
  • Fragomen in Silicon Valley, CA
  • Fragomen in Detroit, MI
  • Fragomen in Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

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

Jenna Robinson

Senior Associate

Fragomen in Irvine, CA, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Fragomen in Atlanta, GA
  • Fragomen in Boston, MA
  • Fragomen in Chicago, IL
  • Fragomen in Miami, FL
  • Fragomen in Dallas, TX
  • Fragomen in Houston, TX
  • Fragomen in Irvine, CA
  • Fragomen in Los Angeles, CA
  • Fragomen in New York, NY
  • Fragomen in Phoenix, AZ
  • Fragomen in San Diego, CA
  • Fragomen in San Francisco, CA
  • Fragomen in San José, Costa Rica
  • Fragomen in Silicon Valley, CA
  • Fragomen in Detroit, MI
  • Fragomen in 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

Fragomen in Irvine, CA, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Fragomen in Atlanta, GA
  • Fragomen in Boston, MA
  • Fragomen in Chicago, IL
  • Fragomen in Miami, FL
  • Fragomen in Dallas, TX
  • Fragomen in Houston, TX
  • Fragomen in Irvine, CA
  • Fragomen in Los Angeles, CA
  • Fragomen in New York, NY
  • Fragomen in Phoenix, AZ
  • Fragomen in San Diego, CA
  • Fragomen in San Francisco, CA
  • Fragomen in San José, Costa Rica
  • Fragomen in Silicon Valley, CA
  • Fragomen in Detroit, MI
  • Fragomen in Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

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

Jenna Robinson

Senior Associate

Fragomen in Irvine, CA, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Fragomen in Atlanta, GA
  • Fragomen in Boston, MA
  • Fragomen in Chicago, IL
  • Fragomen in Miami, FL
  • Fragomen in Dallas, TX
  • Fragomen in Houston, TX
  • Fragomen in Irvine, CA
  • Fragomen in Los Angeles, CA
  • Fragomen in New York, NY
  • Fragomen in Phoenix, AZ
  • Fragomen in San Diego, CA
  • Fragomen in San Francisco, CA
  • Fragomen in San José, Costa Rica
  • Fragomen in Silicon Valley, CA
  • Fragomen in Detroit, MI
  • Fragomen in Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

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

Jenna Robinson

Senior Associate

Fragomen in Irvine, CA, United States

Email

[email protected]

T:+1 949 862 9487

Related offices

  • Fragomen in Atlanta, GA
  • Fragomen in Boston, MA
  • Fragomen in Chicago, IL
  • Fragomen in Miami, FL
  • Fragomen in Dallas, TX
  • Fragomen in Houston, TX
  • Fragomen in Irvine, CA
  • Fragomen in Los Angeles, CA
  • Fragomen in New York, NY
  • Fragomen in Phoenix, AZ
  • Fragomen in San Diego, CA
  • Fragomen in San Francisco, CA
  • Fragomen in San José, Costa Rica
  • Fragomen in Silicon Valley, CA
  • Fragomen in Detroit, MI
  • Fragomen in Washington, DC

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Awards

Citywealth Leaders List: Top 30 Immigration Advisors 2026 Recognises Four Fragomen Professionals

Partners Parisa Karaahmet, Raquel Liberman and Julia Onslow-Cole and Practice Leader Olga Nechita are recognised in Citywealth’s Top 30 Immigration Advisors 2026 for their leadership in advising high-net-worth individuals and families on global mobility and cross-border planning.

Learn more

Work authorization

Family Reunification in Switzerland: Key Scenarios, Requirements and Risks

Manager Quentin Pache outlines the main family reunification pathways available in Switzerland, highlighting key eligibility requirements, procedural deadlines and practical risks that frequently lead to delays or refusals. 

Learn more

Media mentions

The Sunday Times: How to Make Your Move from the UK to the NetherlandsLearn more

Brexit

UK–EU Youth Mobility: Progress, Trade-offs and the Reality of Agreement

UK Government Affairs Strategy Director Shuyeb Muquit explains how a possible UK–EU Youth Mobility Scheme could work in practice, what challenges remain and what it may mean for young people and employers.

Learn more

Awards

12 Fragomen Lawyers Named to 2026 Pro Bono Recognition List

Twelve Fragomen lawyers are recognized on the 2026 Pro Bono Recognition List, reflecting their commitment to providing free legal assistance to those in need.

Learn more

Media mentions

Times Higher Education: Share Agent ‘Bad Actor’ Data With Universities, Home Office Told

Senior Immigration Manager Jonathan Hill discusses new UK guidance suggesting the Home Office may use data to assess agent trust, raising questions about transparency and compliance demands.

Learn more

Video

Understanding Thai Visa Categories: Travel, Work, Study, Retirement and More

In this video, Partner Aim-on Larpisal provides a high-level overview of common Thai visa categories and how they are structured based on purpose of stay, including tourism, work, education and long-term residence.

Learn more

Work authorization

The H-1B Cap Lottery FY 2027 is Complete: What Employers Should Do Next

Partner Chad Blocker outlines what employers should do following completion of the FY 2027 H-1B cap lottery, explains the factors behind lower demand and higher selection rates and highlights key filing risks, timelines and alternative visa options to consider next.

Learn more

Media mentions

EB-5 Investors: May Visa Bulletin Advances EB-5 Dates for Chinese Investors, Cautions Retrogression for India

Senior Counsel Mitch Wexler discusses China’s EB-5 Unreserved category advancing to September 22, 2026, while India’s dates remain unchanged with potential for retrogression amid sustained demand.

Learn more

Media mentions

Citywealth: Tens of Thousands Leave the Gulf for the UK, For Now

Partner Julia Onslow-Cole discusses Middle East-based UHNW clients making short-term moves driven by schooling and timing considerations.

Learn more

Media mentions

Energiewirtschaftliche Tagesfragen: Mitarbeiter aus Drittstaaten im Offshore-Einsatz - Wenn Seemeilen über Legalität entscheiden

Senior Manager Katharina Vorländer examines how immigration rules for offshore wind projects in Germany hinge on nautical boundaries and why careful personnel planning is essential to avoid compliance risks.

Learn more

Media mentions

Gazeta Prawna: Zatrudnienie Kolumbijczyków, Gruzinów i Wenezuelczyków tylko na podstawie wizy i właściwego zezwolenia sprzeczne z ustawą.

Poland Immigration Strategy Director Tomasz Rogala comments on a draft regulation restricting work for citizens of Georgia, Colombia and Venezuela in Poland during visa-free stays.

Learn more

Awards

Citywealth Leaders List: Top 30 Immigration Advisors 2026 Recognises Four Fragomen Professionals

Partners Parisa Karaahmet, Raquel Liberman and Julia Onslow-Cole and Practice Leader Olga Nechita are recognised in Citywealth’s Top 30 Immigration Advisors 2026 for their leadership in advising high-net-worth individuals and families on global mobility and cross-border planning.

Learn more

Work authorization

Family Reunification in Switzerland: Key Scenarios, Requirements and Risks

Manager Quentin Pache outlines the main family reunification pathways available in Switzerland, highlighting key eligibility requirements, procedural deadlines and practical risks that frequently lead to delays or refusals. 

Learn more

Media mentions

The Sunday Times: How to Make Your Move from the UK to the NetherlandsLearn more

Brexit

UK–EU Youth Mobility: Progress, Trade-offs and the Reality of Agreement

UK Government Affairs Strategy Director Shuyeb Muquit explains how a possible UK–EU Youth Mobility Scheme could work in practice, what challenges remain and what it may mean for young people and employers.

Learn more

Awards

12 Fragomen Lawyers Named to 2026 Pro Bono Recognition List

Twelve Fragomen lawyers are recognized on the 2026 Pro Bono Recognition List, reflecting their commitment to providing free legal assistance to those in need.

Learn more

Media mentions

Times Higher Education: Share Agent ‘Bad Actor’ Data With Universities, Home Office Told

Senior Immigration Manager Jonathan Hill discusses new UK guidance suggesting the Home Office may use data to assess agent trust, raising questions about transparency and compliance demands.

Learn more

Video

Understanding Thai Visa Categories: Travel, Work, Study, Retirement and More

In this video, Partner Aim-on Larpisal provides a high-level overview of common Thai visa categories and how they are structured based on purpose of stay, including tourism, work, education and long-term residence.

Learn more

Work authorization

The H-1B Cap Lottery FY 2027 is Complete: What Employers Should Do Next

Partner Chad Blocker outlines what employers should do following completion of the FY 2027 H-1B cap lottery, explains the factors behind lower demand and higher selection rates and highlights key filing risks, timelines and alternative visa options to consider next.

Learn more

Media mentions

EB-5 Investors: May Visa Bulletin Advances EB-5 Dates for Chinese Investors, Cautions Retrogression for India

Senior Counsel Mitch Wexler discusses China’s EB-5 Unreserved category advancing to September 22, 2026, while India’s dates remain unchanged with potential for retrogression amid sustained demand.

Learn more

Media mentions

Citywealth: Tens of Thousands Leave the Gulf for the UK, For Now

Partner Julia Onslow-Cole discusses Middle East-based UHNW clients making short-term moves driven by schooling and timing considerations.

Learn more

Media mentions

Energiewirtschaftliche Tagesfragen: Mitarbeiter aus Drittstaaten im Offshore-Einsatz - Wenn Seemeilen über Legalität entscheiden

Senior Manager Katharina Vorländer examines how immigration rules for offshore wind projects in Germany hinge on nautical boundaries and why careful personnel planning is essential to avoid compliance risks.

Learn more

Media mentions

Gazeta Prawna: Zatrudnienie Kolumbijczyków, Gruzinów i Wenezuelczyków tylko na podstawie wizy i właściwego zezwolenia sprzeczne z ustawą.

Poland Immigration Strategy Director Tomasz Rogala comments on a draft regulation restricting work for citizens of Georgia, Colombia and Venezuela in Poland during visa-free stays.

Learn more

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.