[Blogger’s Note: This post is submitted as a necessarily-lengthy formal comment to the November 20, 2015 draft guidance of U.S. Citizenship and Immigration Services, PM-602-0122, interpreting the phrase, “the same or [a] similar occupational classification” as used in the “increased job flexibility” provisions of Immigration and Nationality Act (INA) §§ 204(j) and 212(a)(5)(A)(iv). This
"Labor Department"
Immigration Triangulation — Another Dysfunctional Government Policy
The dictionary defines the adjective, “passive-aggressive,” as “a type of behavior or personality characterized by indirect resistance to the demands of others and an avoidance of direct confrontation.” That is an apt characterization describing how federal bureaucrats work their will in the immigration ecosphere. The passive-aggressive behaviors show up in efforts by federal immigration officials…
Oh What a Tangled Immigration Web We Weave: A Knotty Future For the H-2B Program
[Blogger’s Note: This post — originally published on March 31, 2013 — is a guest column (updated on April 3, 2013) to reflect actions by the 11th Circuit Court of Appeals and U.S. Citizenship and Immigration Services.
The original post was authored by a former federal government official who played a substantial role in immigration…
Will the new Labor-Business Accord Produce an Immigration Death Panel?
One of the most challenging elements of comprehensive immigration reform (CIR) has long been the need for consensus on the legal, temporary entry of essential foreign workers. This plan for “future flows” of guest workers is critical if we are to reduce the incentive of unauthorized migrants to crash the border.
The lack of agreement between…
Hey, Immigration Bureaucrats: Corporations Are NOT People!
At least by 1602 with the chartering of the Dutch East India Company, and perhaps as early as the 1300s with the formation of the first colleganza, a rudimentary joint-stock company set up in Venice to share the cost of a trade expedition, human beings and corporations have cohabited the earth.
Although the shared habitation of human and…
Has Immigration Fraud Really Gone Viral in the DOL PERM program?
One of the most durable historical myths, Potemkin’s villages, involves the trompe-l’œil hamlets purportedly created at the direction of Grigory Potemkin to impress Catherine II during her 1787 trip to Crimea. If director James Cameron of Avatar fame were to reimagine and modernize the fable of Potemkin’s villages, he might well place the story, in 3D no…
Immigration’s Hobgoblin: A Foolish Inconsistency
Europe is at a tipping point. Will the European Union be dashed on Greek or Italian shores. Will France follow Greece and Italy in losing the esteem of bondholders? Will the EU revert to an Uncommon Market and again suffer its historic curse, a mash-up of competing and warring states whose citizens must proffer passports to…
Immigration Promises Made, Debts Unpaid
Are we a trustworthy nation? The world waits to see if the American government becomes a deadbeat on August 2, when the debt ceiling is hit. Will the country break faith with its creditors? Will it stiff Social Security recipients, the ill and disabled, fallen warriors and others whose lives or fortunes depend on Uncle Sam’s unflagging…