• 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

Podcast

Insight & Impact - Episode 2: Why Data Matters

Canada Managing Partner Cosmina Morariu and Senior Director Leah L. Rogal discuss how immigration, demographic, labor market and economic data can help organizations interpret policy developments, anticipate talent needs and make more strategic workforce and mobility decisions.

Learn more

Fragomen news

Fragomen Opens Denver Office, Strengthening Support for Colorado Employers

Fragomen opens a Denver office to expand immigration support for Colorado employers and growing businesses.

Learn more

Video

Ordinary Naturalisation in Switzerland | #MobilityMinute

Manager Mihaela Dumitru discusses key requirements for ordinary naturalisation in Switzerland, including residence, integration, language skills and local knowledge assessments.

Learn more
Generic Insights

Blog post

Pre-Settled Status and Absences From the UK: When Could Status Be at Risk?

In this blog, Immigration Consultant Mirela Sartori explains when absences could place status at risk, how the Home Office assesses residence and what to do if you receive a “minded to curtail” notice, which generally requires a response within 28 days.

Learn more

Article

Foreign Birth Registration: Mistakes That Can Delay Irish Citizenship Applications

From documentation gaps and certification errors to missed deadlines, Senior Immigration Consultant Patricia Rezmives highlights 8 common FBR pitfalls and how applicants can avoid them.

Learn more

Blog post

Vous envisagez les États-Unis pour la rentrée prochaine ? C'est le moment de préparer votre visa E-2!

Entrepreneurs français : anticipez votre projet d’installation aux États-Unis avec un visa E-2. Découvrez les étapes clés pour préparer votre investissement, votre demande de visa et le déménagement familial avant la prochaine rentrée scolaire.

Learn more

Media mentions

Biometric Update: Fragomen-SICPA JV Adds IDEMIA Biometrics to Assemble End-to-End Identity Platform

Fragomen and SICPA expand their digital identity platform through a strategic collaboration with IDEMIA Public Security.

Learn more

Blog post

Document Legalization Is Becoming a Global Mobility Compliance Issue: Five Trends Employers Should Watch

In this blog, UAE Consular and Document Services Manager Minu Joseph examines five global legalization trends through a Middle East lens—and outlines how employers can prepare earlier to keep assignments on track.

Learn more

Blog post

Doing Business in Qatar: Growth and Workforce Mobility

In this blog, Corporate Services Manager Julia Ignatenko explores why businesses should coordinate company formation, regulatory compliance, leadership presence and workforce mobility from the outset.

Learn more

Awards

Fragomen Wins Immigration Provider of the Year: 2026 FEM APAC EMMAs

Fragomen won Immigration Provider of the Year at the 2026 FEM APAC EMMAs, and our Worldwide Immigration Trends Report 2026 received a Highly Commended recognition in the Thought Leadership category.

Learn more

Media mentions

Forbes: DHS Adds Immigration Rule Stopping H-1B Spouses From Working To Agenda

Partner Kevin Miner discusses DHS’ proposed rule to end employment authorization for certain H-4 spouses of H-1B professionals.

Learn more

Media mentions

Newsweek: Green Card Update: Major Change Announced for Sponsors

Counsel Brian Hunt discussed USCIS’ new ability to obtain credit information from green card sponsors and the potential implications for future regulatory actions.

Learn more

Podcast

Insight & Impact - Episode 2: Why Data Matters

Canada Managing Partner Cosmina Morariu and Senior Director Leah L. Rogal discuss how immigration, demographic, labor market and economic data can help organizations interpret policy developments, anticipate talent needs and make more strategic workforce and mobility decisions.

Learn more

Fragomen news

Fragomen Opens Denver Office, Strengthening Support for Colorado Employers

Fragomen opens a Denver office to expand immigration support for Colorado employers and growing businesses.

Learn more

Video

Ordinary Naturalisation in Switzerland | #MobilityMinute

Manager Mihaela Dumitru discusses key requirements for ordinary naturalisation in Switzerland, including residence, integration, language skills and local knowledge assessments.

Learn more
Generic Insights

Blog post

Pre-Settled Status and Absences From the UK: When Could Status Be at Risk?

In this blog, Immigration Consultant Mirela Sartori explains when absences could place status at risk, how the Home Office assesses residence and what to do if you receive a “minded to curtail” notice, which generally requires a response within 28 days.

Learn more

Article

Foreign Birth Registration: Mistakes That Can Delay Irish Citizenship Applications

From documentation gaps and certification errors to missed deadlines, Senior Immigration Consultant Patricia Rezmives highlights 8 common FBR pitfalls and how applicants can avoid them.

Learn more

Blog post

Vous envisagez les États-Unis pour la rentrée prochaine ? C'est le moment de préparer votre visa E-2!

Entrepreneurs français : anticipez votre projet d’installation aux États-Unis avec un visa E-2. Découvrez les étapes clés pour préparer votre investissement, votre demande de visa et le déménagement familial avant la prochaine rentrée scolaire.

Learn more

Media mentions

Biometric Update: Fragomen-SICPA JV Adds IDEMIA Biometrics to Assemble End-to-End Identity Platform

Fragomen and SICPA expand their digital identity platform through a strategic collaboration with IDEMIA Public Security.

Learn more

Blog post

Document Legalization Is Becoming a Global Mobility Compliance Issue: Five Trends Employers Should Watch

In this blog, UAE Consular and Document Services Manager Minu Joseph examines five global legalization trends through a Middle East lens—and outlines how employers can prepare earlier to keep assignments on track.

Learn more

Blog post

Doing Business in Qatar: Growth and Workforce Mobility

In this blog, Corporate Services Manager Julia Ignatenko explores why businesses should coordinate company formation, regulatory compliance, leadership presence and workforce mobility from the outset.

Learn more

Awards

Fragomen Wins Immigration Provider of the Year: 2026 FEM APAC EMMAs

Fragomen won Immigration Provider of the Year at the 2026 FEM APAC EMMAs, and our Worldwide Immigration Trends Report 2026 received a Highly Commended recognition in the Thought Leadership category.

Learn more

Media mentions

Forbes: DHS Adds Immigration Rule Stopping H-1B Spouses From Working To Agenda

Partner Kevin Miner discusses DHS’ proposed rule to end employment authorization for certain H-4 spouses of H-1B professionals.

Learn more

Media mentions

Newsweek: Green Card Update: Major Change Announced for Sponsors

Counsel Brian Hunt discussed USCIS’ new ability to obtain credit information from green card sponsors and the potential implications for future regulatory actions.

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
September 4, 2026 | DenmarkDenmark: New Immigration Pathway for Certified Employers Hiring Foreign Nationals from Select Countries
September 8, 2026 | United StatesFragomen Opens Denver Office, Strengthening Support for Colorado Employers
September 8, 2026 | RussiaRussia: New Monitoring Application Requirements for Certain Nationals
September 8, 2026 | 🌐Worldwide/Ukraine: Temporary Protection Status - Country-Specific Updates
September 4, 2026 | 🌐Biometric Update: Fragomen-SICPA JV Adds IDEMIA Biometrics to Assemble End-to-End Identity Platform
September 4, 2026 | DenmarkDenmark: New Immigration Pathway for Certified Employers Hiring Foreign Nationals from Select Countries
September 8, 2026 | United StatesFragomen Opens Denver Office, Strengthening Support for Colorado Employers
September 8, 2026 | RussiaRussia: New Monitoring Application Requirements for Certain Nationals
September 8, 2026 | 🌐Worldwide/Ukraine: Temporary Protection Status - Country-Specific Updates
September 4, 2026 | 🌐Biometric Update: Fragomen-SICPA JV Adds IDEMIA Biometrics to Assemble End-to-End Identity Platform
September 4, 2026 | DenmarkDenmark: New Immigration Pathway for Certified Employers Hiring Foreign Nationals from Select Countries
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.