• 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

Fragomen news

Fragomen and SICPA Launch a Global Strategic Joint Venture to Advance Global Digital Identity Solutions

Fragomen and SICPA announced the formation of a global joint venture to advance next-generation digital identity solutions for governments, enterprises and individuals.

Learn more

Blog post

Immigration + Tax: A Strategic Duo in Global Mobility

Senior Associate Kyle Sommer and Adam Schwartz, Director in the Global Mobility practice at Andersen, discuss how immigration and tax considerations intersect across common US immigration classifications and why early coordination can help travelers, employers and advisors reduce compliance risks and make more informed mobility decisions.

Learn more

Podcast

Summer Travel Considerations for Foreign Nationals

In this episode of The Immigration Conversation, Senior Associates Sarah Melnick and Kimberly Elmazi discuss key considerations for foreign nationals planning international summer travel, including visa appointment planning, document preparation, consular interviews, port-of-entry procedures and I-94 review.

Learn more

Podcast

A New PM for the UK: What Will This Mean for Immigration Policy?

UK Government Affairs Strategy Director Shuyeb Muquit is joined by Jonathan Thomas of the Social Market Foundation, Dr. Ben Brindle of the Migration Observatory, University of Oxford and Steve McCauley of the University of Cambridge to discuss what a new UK Prime Minister could mean for immigration policy, employers and workforce mobility.

Learn more

Fragomen news

2026年6月 アメリカ移民法ダイジェスト Learn more

Media mentions

NRC: Iedereen met een Canadese voorouder kan nu staatsburgerschap aanvragen – vooral Amerikanen doen dat

Partner Rick Lamanna said Canada’s expanded citizenship rules could make hundreds of thousands if not millions of people eligible while moving against a global trend of tighter citizenship laws.

Learn more

Media mentions

SBS News: The Overlooked Factor in Australia's Migration Debate That's Keeping Figures High

Senior Counsel Dr. Anna Boucher shares insights on the factors influencing Australia's migration trends.

Learn more

Video

United Kingdom eVisa Process | #MobilityMinute

In this Mobility Minute, Senior Immigration Analyst Nicole Dobromirova discusses updates to the UK visitor visa process, including the shift from visa stickers to electronic visas and how travellers can access their digital immigration status.

Learn more

Media mentions

Bloomberg Law: Justices’ Migrant TPS Ruling Undercuts Pending Court Challenges

Partner Daniel Pierce discussed the implications of the US Supreme Court's latest Temporary Protected Status ruling.

Learn more

Blog post

The EU Pay Transparency Directive: What Global Mobility Leaders Need to Know

In this blog, Senior Counsel Jo Antoon explores what multinational employers need to know about pay transparency, cross-border workers and mobility-related compensation differences as implementation unfolds across the EU. 

Learn more

Media mentions

The PIE: UK Unis Must Treat Compliance as “Strategic Institutional Risk”

Immigration Supervisor Sanjay Parmar discussed how recent UK Basic Compliance Assessment changes are driving universities toward more data-led, proactive compliance management.

Learn more

Blog post

UK Immigration Reforms and Their Impact on the Engineering Talent Pipeline

In this blog, Fragomen’s Nadine Barnole, Jonathan Hill, Anastasia Vasiljeva and Nicole Williams examine how higher Skilled Worker salary thresholds, rising sponsorship costs and proposed Graduate Route changes are making it harder for employers to attract and retain international engineering talent.

Learn more

Fragomen news

Fragomen and SICPA Launch a Global Strategic Joint Venture to Advance Global Digital Identity Solutions

Fragomen and SICPA announced the formation of a global joint venture to advance next-generation digital identity solutions for governments, enterprises and individuals.

Learn more

Blog post

Immigration + Tax: A Strategic Duo in Global Mobility

Senior Associate Kyle Sommer and Adam Schwartz, Director in the Global Mobility practice at Andersen, discuss how immigration and tax considerations intersect across common US immigration classifications and why early coordination can help travelers, employers and advisors reduce compliance risks and make more informed mobility decisions.

Learn more

Podcast

Summer Travel Considerations for Foreign Nationals

In this episode of The Immigration Conversation, Senior Associates Sarah Melnick and Kimberly Elmazi discuss key considerations for foreign nationals planning international summer travel, including visa appointment planning, document preparation, consular interviews, port-of-entry procedures and I-94 review.

Learn more

Podcast

A New PM for the UK: What Will This Mean for Immigration Policy?

UK Government Affairs Strategy Director Shuyeb Muquit is joined by Jonathan Thomas of the Social Market Foundation, Dr. Ben Brindle of the Migration Observatory, University of Oxford and Steve McCauley of the University of Cambridge to discuss what a new UK Prime Minister could mean for immigration policy, employers and workforce mobility.

Learn more

Fragomen news

2026年6月 アメリカ移民法ダイジェスト Learn more

Media mentions

NRC: Iedereen met een Canadese voorouder kan nu staatsburgerschap aanvragen – vooral Amerikanen doen dat

Partner Rick Lamanna said Canada’s expanded citizenship rules could make hundreds of thousands if not millions of people eligible while moving against a global trend of tighter citizenship laws.

Learn more

Media mentions

SBS News: The Overlooked Factor in Australia's Migration Debate That's Keeping Figures High

Senior Counsel Dr. Anna Boucher shares insights on the factors influencing Australia's migration trends.

Learn more

Video

United Kingdom eVisa Process | #MobilityMinute

In this Mobility Minute, Senior Immigration Analyst Nicole Dobromirova discusses updates to the UK visitor visa process, including the shift from visa stickers to electronic visas and how travellers can access their digital immigration status.

Learn more

Media mentions

Bloomberg Law: Justices’ Migrant TPS Ruling Undercuts Pending Court Challenges

Partner Daniel Pierce discussed the implications of the US Supreme Court's latest Temporary Protected Status ruling.

Learn more

Blog post

The EU Pay Transparency Directive: What Global Mobility Leaders Need to Know

In this blog, Senior Counsel Jo Antoon explores what multinational employers need to know about pay transparency, cross-border workers and mobility-related compensation differences as implementation unfolds across the EU. 

Learn more

Media mentions

The PIE: UK Unis Must Treat Compliance as “Strategic Institutional Risk”

Immigration Supervisor Sanjay Parmar discussed how recent UK Basic Compliance Assessment changes are driving universities toward more data-led, proactive compliance management.

Learn more

Blog post

UK Immigration Reforms and Their Impact on the Engineering Talent Pipeline

In this blog, Fragomen’s Nadine Barnole, Jonathan Hill, Anastasia Vasiljeva and Nicole Williams examine how higher Skilled Worker salary thresholds, rising sponsorship costs and proposed Graduate Route changes are making it harder for employers to attract and retain international engineering talent.

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 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
Important Updates
Important Updates
July 8, 2026 | ParaguayParaguay: Economic Solvency Requirements Updated for Permanent Residence Applications
July 8, 2026 | AustraliaAustralia: Fees Increase for Certain Visa Types and Citizenship Applications Effective July 1, 2026
July 8, 2026 | 🌐Fragomen and SICPA Launch a Global Strategic Joint Venture to Advance Global Digital Identity Solutions
July 8, 2026 | JapanJapan: New Residence Permit Fee Structure from October 1, 2026
July 8, 2026 | 🌐Minimum Salary Changes Announced
July 8, 2026 | ParaguayParaguay: Economic Solvency Requirements Updated for Permanent Residence Applications
July 8, 2026 | AustraliaAustralia: Fees Increase for Certain Visa Types and Citizenship Applications Effective July 1, 2026
July 8, 2026 | 🌐Fragomen and SICPA Launch a Global Strategic Joint Venture to Advance Global Digital Identity Solutions
July 8, 2026 | JapanJapan: New Residence Permit Fee Structure from October 1, 2026
July 8, 2026 | 🌐Minimum Salary Changes Announced
July 8, 2026 | ParaguayParaguay: Economic Solvency Requirements Updated for Permanent Residence Applications
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.