Brian Lovin
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Hacker News

I'm Peter Roberts, immigration attorney who does work for YC and startups. AMA

I'll be here for the next 6 hours. As usual, there are lots of possible topics and I'll be guided by whatever you're interested in. Please remember that I can't provide legal advice on specific cases because I won't have access to all the facts. Please try to stick to a factual discussion in your questions and comments and I'll try to do the same in my answers!

Previous threads we've done: https://news.ycombinator.com/submitted?id=proberts.

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1qaboutecs

I never really understood about PERM. Suppose I am a manager on a team and one of my employees is going through the PERM process.

I'm supposed to put out a job advertisement (but the job isn't real) for my employer. If an applicant passes the interview process, I don't have to hire that person (I probably can't - I don't have budget or permission from the organization). But I do have to honestly say if they have all the required skills -- I'm not permitted to say "wouldn't be a culture fit."

Nor do I have to fire my employee. But maybe my employee won't get a green card six years down the road.

1) Do I have any details wrong here? The one time I talked to a law firm about this they more-or-less refused to state the above outright, but answered all questions in this direction. 2) Doesn't this seem disrespectful to, among others, the applicants to the fake job?

proberts

I think everyone would agree that the PERM process is an awful process for both applicants and for employers. The job is supposed to be treated as an open position and the recruitment is supposed to be done in good faith. So, if a qualified, willing, able, and available U.S. worker applies for a PERM job, the employer either must hire this person or terminate the PERM process and wait at least 6 months before restarting it. Now, where there are multiple openings for the position, then it's possible for an employer to hire a U.S. worker without terminating the PERM process for the foreign national employee.

BeetleB

> The job is supposed to be treated as an open position and the recruitment is supposed to be done in good faith. So, if a qualified, willing, able, and available U.S. worker applies for a PERM job, the employer either must hire this person or terminate the PERM process and wait at least 6 months before restarting it.

The "or" part in the last sentence is worth noting. At the place I've worked, the employer invokes the second clause (i.e. PERM process is canceled/suspended, and they try again 6-12 months later).

The way it worked there was: Employer publishes an open req. We get lots of resumes. Manager calls the few people who may be a match. Then the manager has to justify why the person doesn't have the skills and the process continues.

Sometimes (and this is likely a bit random), the government does an audit, where they get the details of all who applied. Then they call the manager and start grilling him on why a particular candidate was rejected. If the manager can convince them, the PERM process continues. If not, they fail the Department of Labor Certification and the PERM process is canceled.

The person doesn't lose his job. They're just ineligible and need to apply again after a certain window.

I do know folks applying for PERM who were rejected twice because of this. The insane thing was that their roles (EE with specific specialty) were legitimately hard to fill, whereas other people in the team doing trivial scripting easily got through PERM.

The process is messed up in many ways.

jmyeet

Generally lawyers need to be involved to make sure any rejections are compliant. There's a whole cottage industry around this.

Personally, given the state of unemployment in the tech sector right now, I think it should be virtually impossible to fill a PERM right now because pretty much any position could be filled with a US LPR or citizen and the only reason it isn't is because the whole process is deliberately obfuscated or artificial barriers are put up purposefully to disqualify candidates.

I also think that doing layoffs in the US should disqualify you from doing any PERM or sponsoring any visa for 2-3 years.

foobiekr

It is well known at the companies that I've worked for that there is no good faith at all in the process and it's basically ritual to justify the application.

Since they are clearly violating the law, how can I report this?

ianhawes

If they've complied with the DOL regulations and requirements, what makes you think they're violating the law?

proberts

The government agencies involved are the DOL and USCIS so you would report abuses/violations to them.

daxuak

Does H1-B really carry that 100k per-case fee? I remember hearing of it, but afterwards also individual stories of people getting H1-B. I don't know them personally unfortunately; not sure whether it was sponsored by not-for-profit research institutes or for-profit companies. I can't imagine this rule being economically feasible for most, though. And if the answer is actually a yes, would the company want to make sure that here's a repayment clause in the contract, e.g. if the worker leaves within X years, he/she will have to refund the company for Y% of this visa fee? Is that even legal?

Related, iirc H1-B has a 6-year limit. Under the current policy what's the path forward if the holder is not ready to adjust their status to PR within the timeframe or not qualified to EB category? O1? But there were a wave of news stories about O1 being abused and I wouldn't be surprised if that was a prelude to major changes to the category.

Just curious. Thanks for making this thread.

proberts

Yes, the $100K fee exists and applies under certain circumstances, essentially if the beneficiary is outside the U.S. or ineligible for a change of status or change of employer. Most companies are simply not pursuing H-1B petitions where the $100K fee would apply but there are exceptions.

It's possible to extend H-1B status beyond the 6-year max-out period if the beneficiary is in the green card process. But if the beneficiary isn't in the green card process, then the most common option is the O-1 and while it's getting harder to get an O-1, it's still within reach of many talented professionals and founders.

cromka

What about recapturing about 2 years of unused H1B and coming back to US for a new position? Does the employer still need to issue the 100k fee? I would imagine they don't, since the visa is already issued, technically speaking?

bubblethink

Also that the fee exists as a proclamation but is being litigated. It is on appeal in the DC circuit and there is a separate case in ND CA as well. In light of learning resources, my money is on it being overruled.

https://www.courtlistener.com/docket/72095497/chamber-of-com...

https://www.courtlistener.com/docket/71541425/global-nurse-f...

jjmarr

How has AI affected your job and what tools are you using?

What's an ask you'd make to startups in the legal AI space?

Not selling something, but have heard primarily negative sentiments from other lawyers due to hallucination risk.

proberts

We're not using AI much at all. We're using it a bit to search and organize documents but not much beyond that. It's almost always a little wrong when responding to immigration-related questions/providing immigration legal advice and a little wrong makes it completely unreliable except as a first step in trying to get answers.

aliljet

What systems are you actively using? And what systems have you tried? It seems like law, generally, may be hitting a tipping point on LLM use...

kingstoned

If someone is from one of 75 countries with ban on immigration but also has dual citizenship from a country that is not banned, do they need to go to that second country's US embassy when applying for an immigration visa?

xqb64

What's the best path from zero to a fully legal status (visa first I imagine, but eventually citizenship) in the US for someone coming over from the Western Balkans (non-EU), with a bachelors degree in EE or CS and no prior work experience? Thanks for doing this.

proberts

The options are limited: an H-1B for employment (which involves an annual lottery), an F-1 for schooling, or a J-1 for internship/training (which requires a "host" company/employer).

bigdollopenergy

OP didn't state their exact country, but E-2 visa may be applicable. It's not just for investors/business starters. Companies that are privately owned by people from E-2 countries can transfer/hire citizens from other E-2 countries. Probably the most realistic option for a junior/mid-level developer IMO. See if your country is an E-2 country and apply to companies that qualify. E-2 is a non-immigrant visa so moving onto green card is more difficult but not impossible.

There's also the L1B Company transfer, if you work for a company with offices in the US and they would be able to transfer you after a year. Bit of a gamble to find a company that would be willing to do this though, and you gotta work for probably years to find out.

H-1B, if you're not already in the US has a 100k fee attached to it. Though AFAIK that was a proclamation that expires at some point, but probably won't. So it's really not an option for 99% of people.

I'm not a lawyer, so definitely verify what i say, but i'm pretty sure these are also valid options.

xqb64

I'm sorry, Serbia. According to [0], it seems like E-2 would be applicable, too.

Thank you.

[0]: https://www.usimmigrationadvisor.com/active-e-2-treaty-count...

proberts

Thanks! Very good points. The E-2 is also a great option for founders (with their own funding or with funding from citizens/VCs from their own country).

throwaway2037

Another idea: Get a master's degree in the US. Expensive, but will give you a very good chance to get a job offer in US. PhD is even better, but will take 4-5 years.

Also: Try the green card lottery. You can Google to find info.

mettamage

When you have an IR-1 in the process, but we decided to move to Europe is it then better to cancel that application or is it better to just let it go through the system and sort of cancel it at the point when we're invited for an interview?

dwa3592

Thanks for doing this.

- How difficult has it become to get O1 for founders compared to say 5 years ago?

-What advice would you have for founders who think they should be able to get O1 once they have a bit of seed money (say YC, 500k) and press coverage?

proberts

It's definitely more difficult but well within reach of founders (particularly founders with funding and organic press coverage) and talented professionals. That is, until very recently. It's too early to say whether this is a trend or an aberration but the past few weeks we've seen USCIS apply a different standard, one similar to the EB1A standard. If this is a trend, then I suspect that the RFE and denial rates for O-1s will skyrocket.

mifydev

Is it just aligning to EB1A standards, or more rigorous and picky process in general?

jnsaff2

There are suggestions[0] that the crooks running the country atm are trying to use the EB1 visa quotas for the golden visas instead.

[0] https://www.youtube.com/watch?v=zA3qrg2Kpbo

jefftk

What are you seeing with the new $100k H1B fee? Is it being applied only to people currently outside the US? Do you have any estimates on whether it's likely to be renewed in September and/or struck down?

proberts

It's being applied to those outside the U.S. or those in the U.S. who are ineligible for a U.S.-based change of status or change of employer. This fee primarily has impacted employers seeking to hire people who are outside the U.S. and also limited when people can travel,

Aarostotle

What's the climate like around TN visas nowadays? Specifically, from Canada to the US. (Thinking of Waterloo grad-types but also humanities types coming to join in non-eng roles)

proberts

Since a Canadian TN can be applied for when traveling to the U.S. from Canada, it's a very fast process and still generally easy for Canadians with engineering degrees.

proberts

Thank you for all the great questions and comments. I will be taking a brief break.

mikeyouse

Our small company offers a remote paid mentorship for students anywhere in the world - often times, international students in the US want to apply but then there’s substantial confusion on whether they can be paid without jeopardizing their status. The stipends we pay are all 1099 and it’s mostly self-directed work so we’re a bit at a loss in regards to the CPT/OPT qualifications. Many end up forgoing their stipend which sucks for students in an expensive place.

Any thoughts there?

throwaway219450

Maybe Peter can comment further, but my impression was that the definition of "work" is normally unrelated to whether it's paid or not, for F/J?

If those students are actually concerned about staying in status, simply saying they're volunteering might not be sufficient.

proberts

That's right. Working without pay in jobs that normally are paid could still be considered unauthorized employment.

proberts

The students should speak with their DSOs (Designated School Officials) because they must have work authorization to get paid whether they're paid by a U.S. or foreign source or paid as a 1099 contractor or W-2 employee. But I don't see why both CPT and pre-completion OPT wouldn't work.

stardek

Are you able to comment on J-1 visa limitations around duration of international travel?

I'm a postdoc at a US university. My school's international office suggested there was no limit on how long I could travel outside of the US, but most sources online suggest there is a limit of 30 days before the SEVIS record goes inactive. It seems this can be avoided if the university sponsor records the travel in SEVIS. I think I've finally convinced them that this is a real limitation, but some actual expert knowledge would still be very appreciated! I am Canadian, in case that affects the answer.

Thanks for doing this!

proberts

My understanding is that time outside the U.S. of more than 30 days while in J-1 status is permissible but triggers a SEVIS alert and requires the ISSO to verify in the SEVIS system that you are continuing with your J-1 work while outside. So, you would want to advise the ISSO before you leave the U.S. and get his or her okay.

MITSardine

Not an attorney so I don’t know the details but it is definitely possible to leave the US several months in a row on a J1. When I did it (also as postdoc), it was an involved process that escalated to the (vice?)president’s office to get permission so there are clearly questions the university needed to address... I didn’t have any visibility into it all but what I was told about regarded taxes mainly (since getting paid abroad).

So technically possible but also a tall ask (I didn’t know at the time of asking and my PI went with it).

I then came back and carried on without any immigration issues.

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