Most people who want to work in the United States will only be able to qualify for either H-1B or L-1 status, although you can find a list of other work visas on the general FAQ. There are a number of reasons why the H-1B visa may be regarded as more desirable, but it is also difficult to obtain because of the annual lottery. The low probability of winning the lottery discourages employers from sponsoring candidates for H-1B visas. The L-1 visa is a practical alternative as it has no annual quota and therefore no lottery.
The L-1 visa has different requirements from the H-1B visa. In particular, the alien does not need to prove that they have specialized knowledge about the field they work in; instead, to obtain an L-1B visa, it is only necessary that they have specialized knowledge about the operations of the company that is transferring them to the United States. Thus, even a person without a post-secondary degree can qualify for an L-1B visa, whereas qualifying for an H-1B visa would be much more challenging. To obtain an L-1A visa, the alien must be coming to the United States in a managerial capacity.
The spouse of an L-1 visa holder is authorized by the Immigration and Nationality Act to be employed without restriction [1][46]; this benefit is not extended to the spouses of TN, O-1, or H-1B1 workers. While spouses of H-1B workers may qualify for employment authorization, this benefit is generally not available immediately since it requires the H-1B principal to have proceeded to a certain stage of the [EB.md](employment-based green card process).
The biggest disadvantage to L-1 status is that it does not provide any easy way to change employers while in the US. For this reason, many L-1 employees will seek to eventually transition to H-1B status. Besides that, Indian applicants for an employment-based green card may eventually max out their allowable stay in L-1 status and must also switch to H-1B status in order to avoid disruption to their employment in the US. We will discuss these issues further below.
An L-1 is a nonimmigrant alien who [23]:
within 3 years preceding the time of his application for admission into the United States, has been employed continuously for one year by a firm or corporation or other legal entity or an affiliate or subsidiary thereof and who seeks to enter the United States temporarily in order to continue to render his services to the same employer or a subsidiary or affiliate thereof in a capacity that is managerial, executive, or involves specialized knowledge
There are therefore two criteria that must both be satisfied:
- Within the 3 years before applying for L-1 status, the alien has worked outside the United States for at least one continuous year for some company and is now applying to work for the
same
company in the US (we won't get into the specifics of what this means). - The alien's employment in the US must be in a managerial or executive capacity, or involve
specialized knowledge
.
To be more specific:
- An alien is considered to have
specialized knowledge
if:the alien has a special knowledge of the company product and its application in international markets or has an advanced level of knowledge of processes and procedures of the company.
[24] In other words, the specialized knowledge possessed by the alien must pertain specifically to the company; it is not sufficient to merely have specialized knowledge related to the alien's occupation [28]. However, according to USCIS, specialized knowledge does not necessarily need to beproprietary or unique
to the petitioner. [33] - An employee may come to the US to open a new office provided that the necessary relationship exists between the US entity and the foreign entity [26].
- The qualifying year of employment must have been outside the US [25][26]. Thus, any time spent working for the same employer in the US does not count toward the one year requirement.
- Both the qualifying year of experience abroad, and the intended employment in the US, must be in a managerial, executive, or specialized knowledge capacity [26]. However, they don't have to be in the same capacity. For example, a specialized knowledge employee outside the US could be transferred to the US to be a manager or vice versa. [27]
L-1 status does not have restrictions as to the occupation of the employee, and may therefore be available to employees whose occupations do not qualify them for H-1B status. Many employees at multinational corporations could potentially qualify for a transfer to the US in L-1 status. However, if USCIS believes that a company is using the specialized knowledge category to transfer employees who are merely skilled workers and do not possess a significant level of specialized knowledge about the company, this can attract additional scrutiny of L-1 petitions.
L-1A and L-1B are petition-based classifications; an L-1 visa or change of status to L-1 cannot be granted unless the employer has filed an appropriate petition [2]. There are two types of L-1 petitions: individual petitions and blanket petitions. An individual petition is an application to classify a single alien beneficiary. A blanket petition is an application to USCIS to pre-approve the company to transfer employees to the US, including future employees whose identities and number are not yet known. Individual and blanket petitions are both filed on Form I-129 [3]. You don't have to worry about this form too much, since it will always be prepared by your employer or by a lawyer on your employer's behalf. However, we will make occasional references to it.
The two petitioning procedures will be discussed below. In both cases, keep in mind that the beneficiary will usually be required to apply for a visa in order to apply for admission to the United States in L-1 status.
The I-129 petition must be approved in order for an alien to receive a visa. It is not required to present a the physical approval notice (I-797) to the consular officer [4] but many lawyers will recommend carrying a copy to the interview anyway.
The consular officer will annotate the visa with the name of the petitioner (employer), the petition receipt number, and the expiration date of the petition [5]. The CBP Inspector's Field Manual states that such an annotated visa is sufficient for admission [6], however many lawyers will recommend carrying a copy of the approval notice just to be safe.
If the beneficiary is visa-exempt, then they must present a copy of the approval notice at the port of entry in order to be admitted in L-1 status [6] (however, there are special rules for Canadian citizens, for which see below).
Due to the requirements of L-1 status, it is uncommon to apply for L-1 status while already in the United States; however, it is not impossible. An employer can request to change the status of an alien to L-1 at the time when it files the Form I-129 [7][10]. The adjudication of such a request is a two-step process, in which USCIS first determines whether the beneficiary qualifies for intracompany transferee classification, and then determines whether the beneficiary qualifies to change their status to L-1 while in the United States [8]. Usually, both steps will be approved, in which case USCIS sends Form I-797A, containing an I-94 indicating the new L-1 status and authorized period of stay [9]. However, it's possible that the petition is approved while the change of status is denied—typically because USCIS has determined that the beneficiary has violated their status, making them ineligible for a change of status—and the beneficiary must usually leave the United States and apply for a visa or for status at the port of entry.
When USCIS approves a blanket I-129 petition, the employer will receive an I-797 approval notice.
Form I-129S is used to request classification of a particular alien employee based on a blanket I-129 petition that has already been approved [11]. Form I-129S will be adjudicated by the consular officer at the time of visa application. In order for the employee to apply for the visa, the employer must complete Form I-129S and give the employee in question the original and two copies. The original and each copy of Form I-129S that are given to the employee must be attached to a copy of the approval notice of the blanket petition, and the employee must present the original and both copies to a consular officer to apply for an L-1 visa [12].
The consular officer may only approve the Form I-129S and grant the visa if they determine that the I-129S is clearly approvable
, that is, the alien in question clearly qualifies for specialized knowledge, executive, or managerial classification with respect to the sponsoring employer [13]. If there is any doubt that the applicant qualifies, the consular officer will deny the application under INA 221(g). The employer then has the option of filing an individual L-1 petition for the employee under the procedure described in the previous section. [14]
When the consular officer approves Form I-129S, they will stamp the original and both copies, return the original and one copy to the applicant, and retain the second copy for their records [17]. At the port of entry, the employee must present the visa together with a copy of both the I-797 approval notice for the blanket petition, and the approved Form I-129S [15].
If the beneficiary is visa-exempt, form I-129S may be adjudicated by USCIS. The employer must file an original form I-129S with one copy, both of which have the I-797 approval notice for the blanket petition attached. If USCIS approves form I-129S, it will stamp both the original and the copy, returning the original to the employer and retaining the copy [16][18]. Again, the employee would have to present the I-797 and the stamped I-129S at the port of entry in order to be admitted. However, there are also special procedures for Canadian citizens, for which see below.
If the employee is already in the United States in some other nonimmigrant status and their employer wishes to change their status to L-1, the employer must submit Form I-129 and Form I-129S together to USCIS [19]. See the section on individual petitions for a discussion of the adjudication process for L-1 change of status petitions.
Canadian citizens do not require L-1 visas. Consular officers therefore do not play a role in the adjudication of eligibility for L-1 status in the case of Canadian citizens (unless the Canadian citizen specifically decides to apply for a visa for some reason).
In individual L-1 cases, an original Form I-129 and one copy, together with supporting documentation and fees may be filed at the port of entry by the Canadian citizen seeking entry; the employer does not need to submit it to USCIS in advance of the employee's entry to the US [20]. If it is approved, the CBP officer will place an approval stamp, issue, an I-94, and forward the original I-129 to USCIS, which will eventually issue an I-797 approval notice [6].
An employer is not required to have the CBP officer adjudicate the individual L-1 petition for a Canadian employee. The employer may opt to file Form I-129 with USCIS in advance just as they would for a non-Canadian employee [22]. In this case, the I-797 approval notice could be used by the Canadian employee for admission to the US.
In blanket L-1 cases, the alien must present one original I-129S and two copies at the port of entry, together with the required fee and supporting documentation. The original and both copies must each have an attached I-797 approval notice for the blanket petition [21]. Again, the employer is not required to avail itself of this procedure; advance filing of Form I-129S also appears to be allowed [22]. However, the instructions for this are not clear.
An L-1 nonimmigrant will receive an I-94 upon admission which determines their allowable period of stay unless it is extended afterward. This section explains how long you can generally expect to be admitted for; however, as always, the actual period of allowable stay will be determined by CBP at the time of admission and will be reflected on the issued Form I-94.
An individual petition can be approved for up to 3 years [30]. The beneficiary can enter the US up to 10 days before the petition validity begins, and will normally be issued an I-94 that expires 10 days after the petition expires [29]. However, the petition only grants the employee work authorization during the petition validity, and not during the 10 day periods before and after.
An employee admitted under a blanket petition will normally be admitted for 3 years even though the blanket petition may expire before the end of the 3 year period [31]. For example, suppose a blanket petition was valid from Jan 1, 2010 to Dec 31, 2012. Suppose an employee was transferred using this petition, and was admitted on Jan 1, 2012, receiving an I-94 valid until Dec 31, 2014. Initially, the employee would only have work authorization until the expiration of the petition, Dec 31, 2012. However, if the employer filed for and obtained an extension of the blanket petition, the employee's work authorization would have been automatically extended until Dec 31, 2014 and no additional action would be required for the employee to complete their full 3 year period of authorized admission ending on Dec 31, 2014.
If a blanket petition expires during a beneficiary's 3 year period of admission, and the employer decided not to extend the blanket petition, or the extension petition were denied, the employee's work authorization expires together with the petition expiration (in the example above, the beneficiary's status would have expired on Dec 31, 2012 even though their I-94 is valid until Dec 31, 2014). However, the employer can file an individual L-1 petition in order to extend the employee's status beyond the expiration of the blanket petition. If the employer also chooses not to do this, the employee could not continue to maintain L-1 status after the blanket petition's expiration and would have had to switch to another status or leave the US. [31]
To summarize, admitting the employee for 3 years, even though the blanket petition might expire earlier, is a practice that affords convenience to the employer and employee in the common case where the petition validity is later extended, but it does not mean the employee will automatically get 3 years if the employer does not obtain the extension.
A beneficiary of a blanket petition who travels outside the US and then returns to the US to resume work for the petitioner will normally be readmitted for a new 3 year period (not for the remainder of the initial 3 year period) [6] unless this would exceed the maximum period of allowed stay (see below).
For L-1B (specialized knowledge), the maximum period is 5 years. For L-1A (managerial and executive), the maximum period is 7 years. Only days during which an employee is actually in the US count toward this limit, so it is possible to recapture
time spent on brief trips abroad [34]. Time spent in L-2 status does not count toward the limit [35]. Once the limit is reached, it is not possible to extend L-1 status anymore. If the employee wishes to continue in L-1 status, they must first spend at least 1 year physically outside the US [32].
There is no AC21 exemption to the 5- and 7-year limits for L-1 employees. Therefore, an L-1 employee who is pursuing a green card, but may not able to file for adjustment of status before the limit is reached, should attempt to switch to H-1B status in order to be able to continue extending their stay in the US pursuant to AC21.
Note that time spent in L-1 status also counts toward the 6 year limit on H-1B time. Thus, if an L-1B worker has used their full 5 years, they would normally only be eligible for 1 year in H-1B status unless they first leave the US for a year; however, they may qualify for an AC21 exemption to this limit. If an L-1A worker has used their full 7 years, or at least 6 years out of the 7, it is not clear whether AC21 can be used in this situation, so said worker might not be able to obtain H-1B status at all without first leaving the US for 1 year.
The extension procedures are different for individual and blanket petitions. We will discuss both below. In both cases, an extension of stay can be granted for up to 2 years at a time [37]. Keep in mind that there is a maximum period of stay for L-1 nonimmigrants (discussed above) and no further extensions could be granted beyond that period. Thus, an L-1B employee initially admitted for 3 years could receive one extension of 2 years. An L-1A employee initially admitted for 3 years could receive up to two extensions of 2 years each.
The beneficiary of an individual petition may have their stay extended by the filing Form I-129 if they are physically present in the US and meet the other requirements for extension of stay. Since L-1 status requires an approved petition, the filing of Form I-129 to extend the employee's stay is also a request to extend the petition [36]. (As an alternative, the employer could seek to extend the petition alone. In that case, the employee would need to leave the US, possibly obtain a new visa if the previous L-1 visa had expired, and be re-admitted in order to obtain a new I-94 with the new expiration date.)
The request to extend the petition and the request to extend the employee's stay are adjudicated as two separate steps. The employee's stay cannot be extended if the petition extension is denied. If the petition extension is approved, then the employee's extension of stay will usually also be approved. In that case, the employee would receive a new I-94 [39] whose expiration date would be that of the extended petition [36], plus (usually) a 10 day grace period [29]. However, since USCIS is required to make a separate determination regarding the petition extension and the extension of stay, it is possible for the former to be approved and the latter denied (such as if the beneficiary has failed to maintain status and therefore cannot receive an extension). In that case the employee would need to leave the US and be re-admitted to the new expiration date. They would also need to apply for and receive a new L-1 visa if their previous L-1 visa had already expired.
Recall from above that a blanket petition is initially approved for a period of 3 years and, if an extension is granted, then the blanket petition will remain valid indefinitely. However, an individual employee will be admitted for up to 3 years at a time, as discussed above. Thus, if an employee is admitted under an initial blanket petition, the employer must apply to extend the blanket petition on Form I-129 [38] and must also apply for the employee's extension of stay. If an employee is admitted under an indefinitely valid blanket petition, the employer must still apply for the employee's extension of stay.
If the employer fails to extend the blanket petition, or the extension of the blanket petition is denied, then the work authorization of each employee who was admitted based on that blanket petition will expire when the original blanket petition expires, and the employer would be required to file an individual L-1 petition for each employee in order to continue employing them beyond that date [31].
Assuming that the employer already has indefinite blanket validity, or has filed the necessary extension for the blanket petition, the procedure for requesting the employee's extension of stay based on the blanket petition involves filing Form I-129 together with a new Form I-129S [19][36]. If the extension of stay is approved, the employee will receive a new I-94 [39].
Unfortunately, USCIS materials do not seem to give a clear description regarding denials of extensions based on blanket petitions. It can be assumed that the individual petition process is still available if the employee's extension based on a blanket petition is denied. However, online materials do not give a clear answer as to whether an employee who is ineligible for an extension of stay (for example, due to untimely filing) could still receive an I-129S approval notice that could be used to apply for a visa abroad without the need for an additional petition.
It is possible for an L-1 employee who was admitted based on a blanket petition to receive an extension of stay based on an individual petition. As discussed previously, this can happen if the employer's petition to extend the blanket petition is denied or if the employer could not file for a blanket petition extension for some reason.
It is not clear from USCIS materials whether an employee initially admitted under an individual L-1 petition could seek an extension based on a blanket petition.
This is usually not possible. As discussed above, you can obtain L-1 status to work at a company in the US only if you have already worked at the same
company (generally a parent or subsidiary) abroad for at least 1 year during the previous 3 years. Thus, if you are already in the US working in L-1 status, and you wanted to begin working for another company in L-1 status, you would need to also be able to prove that you worked for the new company abroad for at least 1 year out of the last 3 years. This is not a condition that is typically met.
It is much easier to switch employers if the new employer can sponsor you for H-1B or O-1 status.
The requirements for the L-1A classification are similar to those of the EB-1C classification. Nevertheless, there is no automatic
conversion between the two. An L-1A employee who wishes to pursue an EB-1C green card must still have their employer file an I-140 petition on their behalf for the EB-1C classification, and such petition will be reviewed in the same manner as any other EB-1C petition. Furthermore, it is possible for an employee to run out of L-1A time (use up all 7 years) before they become eligible to file for an EB-1C green card. In such cases, the employee must generally seek to change to H-1B or O-1 status in order to continue working in the US while they wait for their priority date to become current.
The L-1 classification has three major advantages over H-1B, which were mentioned previously:
- It is not numerically limited, and thus can be obtained at any time of year without the uncertainty of going through a lottery process.
- All L-2 spouses can obtain employment authorization [1]. Although some H-4 spouses are also eligible for employment authorization, it is not immediate (since it can only be obtained after reaching a certain stage in the green card process) [40] and may be subject to revocation by the Trump administration.
- You can obtain L-1 status even if your occupation or your educational background does not qualify you for H-1B status.
However, L-1 also has two major disadvantages. One is that there is no easy way to change employers in L-1 status, whereas it is usually straightforward to switch employers in H-1B status. The other is that there is no way to extend L-1 status beyond the time limit (7 years for L-1A, 5 years for L-1B). If you are waiting to be able to file for a green card, and you are at risk of running out of L-1 time, then it is best to switch to H-1B, or O-1 if you are eligible. The H-1B can be extended indefinitely if you have an approved I-140 and are waiting for a green card to become available [41], and the O-1 can be extended indefinitely until the time of I-485 filing.
Thus, for an L-1 employee who is not married and not planning on getting married in the near future, and who meets the requirements for H-1B status, there are significant advantages and almost no disadvantages in trying to get their employer to switch them from L-1 status to H-1B status as early as possible. This may require several tries (since the employee may not be able to win the lottery on the first entries or even the first few entries). Until H-1B status is obtained, there is no easy way to switch employers and the risk of running out of L-1 time looms over your head.
Some people think that L-1A status is better
than H-1B because it makes them eligible for an EB-1C green card. However, technically there is no requirement for an EB-1C green card applicant to have ever held L-1A status, as the qualifications for L-1A and EB-1C are separate (despite being similar). Furthermore, switching to H-1B status does not invalidate an EB-1C I-140: that is, if someone is waiting for an EB-1C green card, they can stay in line
even if they switch to H-1B status.
Any L-2 nonimmigrant who is in status as the spouse of an L-1 nonimmigrant is considered employment authorized incident to status
[46]. This means that by virtue of their status alone, they are allowed to work in the United States and do not need any additional permission from USCIS. An L-2 nonimmigrant may take up employment in any field of their choice, since there are no restrictions specified in the Immigration and Nationality Act [1].
This was not always the case. In the past, USCIS required L-2 spouses to obtain an EAD before being allowed to work. Accordingly, the I-9 regulations [47] do not permit employers to employ L-2 nonimmigrants purely based on evidence of their status as an L-2 spouse; they must present an EAD. This policy was challenged in the Shergill et al. v. Mayorkas case [48], alleging that USCIS policy was contrary to law. On November 10, 2021, the case was settled, with DHS agreeing that L-2 spouses are considered employment authorized incident to status.
As part of the settlement, DHS agreed that USCIS and CBP will make changes to Form I-94 such that it will indicate whether the holder is an L-2 spouse. Once such updated I-94s are available, they will be usable as evidence of employment authorization. Therefore, the holder of such an updated I-94 will not need an EAD in order to work for any employer in the United States. Until such updated I-94s are available, L-2 spouses will still need an EAD in order to work for an employer in the United States, but will not need an EAD in order to be self-employed in the United States (since self-employment does not require I-9 verification).
L-2 spouses who have an I-94 indicating the class of admission L-2S
(possibly without the hyphen), or who have received a notice from USCIS indicating that it can be used for I-9 verification, do not need EADs at all and can skip this section [50]. L-2 spouses who are self-employed or otherwise exempt from I-9 requirements do not need any documentation at all in order to work in the US, as long as they ensure that they maintain L-2 status, and can likewise skip this section.
L-2 spouses who need an EAD may benefit from the 180 day automatic EAD extension rule [46], thanks to the Shergill settlement [48]. To be precise, if:
- An L-2 spouse already has an L-2 EAD; and
- The L-2 spouse has applied for a renewal of their L-2 EAD prior to the expiration date on the card; and
- The applicant has an I-94 indicating L-2 status that will expire later than their EAD, and is still maintaining this status;
then the L-2 EAD will be considered automatically extended until the expiration date of the I-94, but not to exceed 180 days. The automatic extension will terminate when USCIS issues a decision on the renewal EAD application.
The work visa ban [42][45] expired at the end of March 31, 2021 and is thus no longer in effect. Due to the Proclamation, L-1A, L-1B, and L-2 visas were not issued between June 24, 2020 and March 31, 2021, except to individuals who fell under one of the following exemptions:
- Persons who were physically present in the US on June 24, 2020 at 12:01 AM ET
- Persons who possessed an L-1 visa that is valid on June 24, 2020 at 12:01 AM ET
- Persons who possessed an advance parole document or other travel document issued by the US, which was valid on June 24, 2020 at 12:01 AM ET
- Spouses and children of US citizens
- Persons whose job in the US was essential to the US food supply chain, in the opinion of the State Department or DHS
- Persons whose entry to the US would be in the national interest, for example, for national security or defense reasons, or because they are involved in health care related to COVID-19. This determination was be made by the State Department or DHS.
There has been some confusion over how the State Department interpreted the exemptions. Please see the H-1B FAQ for more details regarding this situation (but replace H-1B
with L-1
, and H-4
with L-2
). In any case, a person who has a valid L-1 visa and who remains eligible for L-1 status, or who has a valid L-2 visa and remains eligible for L-2 status, can still use their valid visa to enter the US.
Since the Proclamation only affected visa issuance, it did not affect the ability of Canadian citizens to enter the US in L-1 or L-2 status, since they do not require visas in order to apply for L-1 or L-2 status at the port of entry. Canadian citizens could still enter the US in L-1 status if they have a valid petition approved by USCIS, even if they did not fall under any of the exemptions listed above. [43][44]
No. A visa is distinct from status. A visa is also not the same thing as an L-1 petition. The proclamation [42], as written, applieed to visas, and therefore did not affect the approval of L-1 petitions or Extension of Stay based on an L-1 petition. Similarly, extensions of L-2 status and Change of Status to L-2 were unaffected.
[1] INA 214(c)(2)(E) (8 USC §1184(c)(2)(E))
[2] Ibid., (c)(1)
[3] 8 CFR §214.2(l)(2)
[4] 9 FAM 402.12-5(B)
[5] Ibid., 402.12-7(D)
[6] CBP Inspector's Field Manual, 15.4(l)
[7] USCIS-AFM 30.3(a), archived August 24, 2019
[8] Ibid., (d)(3)
[9] Ibid., (d)(7)(A)
[10] Instructions for Petition for Nonimmigrant Worker
[11] https://www.uscis.gov/i-129s
[12] 8 CFR §214.2(l)(5)(ii)(A)
[13] Ibid., (l)(5)(ii)(E)
[14] Ibid., (l)(5)(ii)(F)
[15] Ibid., (l)(13)(i)
[16] Ibid., (l)(5)(ii)(C)
[17] 9 FAM 402.12-8(F)
[18] USCIS-AFM 32.5(d), archived August 24, 2019
[19] Instructions for Form I-129S
[20] 8 CFR §214.2(l)(17)(i)
[21] Ibid., (l)(17)(ii)
[22] Ibid., (l)(17)(iii)
[23] INA 101(a)(15)(L) (8 USC §1101(a)(15)(L))
[24] INA 214(c)(2)(B) (8 USC §1184(c)(2)(B))
[25] 8 CFR §214.2(l)(1)(i)
[26] Ibid., (l)(3)
[27] USCIS-AFM 32.3(b), archived August 24, 2019
[28] 9 FAM 402.12-14(E)
[29] 8 CFR §214.1(l)
[30] 8 CFR §214.2(l)(7)(i)(A)(2)
[31] Ibid., (l)(11)
[32] Ibid., (l)(12)(i)
[33] USCIS-AFM 32.6(e)(2)(B), archived August 24, 2019
[34] Ibid., (g)
[35] Ibid., (h)
[36] 8 CFR §214.2(l)(15)(i)
[37] Ibid., (l)(15)(ii)
[38] Ibid., (l)(14)(iii)
[39] USCIS-AFM 30.2(d)(7)(A), archived August 24, 2019
[40] 8 CFR §214.2(h)(9)(iv)
[41] Ibid. (h)(13)(iii)(E)
[42] Proclamation Suspending Entry of Aliens Who Present a Risk to the U.S. Labor Market Following the Coronavirus Outbreak
[43] Seyfarth Shaw LLP - FAQ - New Proclamation Suspending Entry of H-1B, L-1, J-1, and H-2B Nonimmigrant
[44] https://twitter.com/gsiskind/status/1275888516459827200
[45] Proclamation on Amendment to Proclamation 10052
[46] USCIS Policy Manual, Volume 10, Part B, Chapter 2
[47] 8 CFR §274a.2(b)(1)(v)
[48] https://www.wasdenbanias.com/shergill
[49] 8 CFR §274a.13(d)
[50] https://www.uscis.gov/sites/default/files/document/policy-manual-updates/20220318-EmploymentAuthorization.pdf