Understanding Visa Nuances Surrounding International Hotel Task Force Options
By Jerome G. Grzeca
This article was co-authored by Megan Call, Immigration Attorney, Grzeca Law Group
In the global hospitality industry, hotels often face circumstances that require swift and strategic staffing solutions. Task force staffing, or deploying experienced professionals temporarily across related hotels, has become a vital tool for international hotel companies navigating the need for backfilling positions such as maternity leave, sudden terminations, medical emergencies, professional development plan (PDP) oversight, training initiatives, financial audits, and rapid growth.
These can require a range of time, from a few weeks to several months, depending on the complexity and urgency of the situation. To meet these needs efficiently, hotel groups frequently leverage talent from “sister properties” within their portfolio. This internal mobility allows for continuity of brand standards and operational consistency. However, when task force assignments cross international borders, legal considerations such as work permits, visa requirements, and labor law compliance come into play, making it essential for hotel executives to understand the legal framework surrounding these deployments.
While business visitor status may suffice for limited, non-productive engagements, many task force assignments in the hospitality industry go beyond observation and oversight. To ensure compliance, hotels must be familiar with the range of work authorization options available for transferring employees to the U.S. The following sections outline key visa categories that support task force staffing, including those tailored to specific nationalities, company structures, and project-based assignments.
Work Authorization Options for Task Force
Legal issues arise when business visitor activities begin to resemble employment. Risk areas can include supervising hotel staff or making operational decisions, conducting training of others, participating in day-to-day management, delivering services that impact guest experience, and receiving compensation from a U.S. entity. Even if the task force member continues to receive compensation from the sister property outside the U.S., these activities may be considered unauthorized employment under U.S. law. If the task force assignment involves any of these, then the individual must obtain proper work authorization. Whether the assignment lasts two days or two months, if the individual is performing services, they must have the appropriate work authorization.
The B-1 visa allows foreign nationals to enter the U.S. for legitimate business activities that do not involve “performing services.” Permissible activities include attending meetings or conferences, consulting with business associates, receiving training, and negotiating contracts. These roles are typically advisory or observational and do not involve managing U.S. employees, interacting with guests, or performing services that generate revenue.
When deploying international task force staff to the U.S., hotel executives must carefully distinguish between business visitor activities and employment, a line that can be surprisingly easy to cross. U.S. immigration law focuses on activity, not length of stay. While some short-term assignments may not require work authorization, others do, regardless of duration. Certain activities fall under the umbrella of business visitor status, which typically allows individuals to enter a country without work authorization for limited, non-productive engagements.
Business Visitors
Noteworthy for most of the following categories is “intermittent” visa status, which essentially allows the task force employee to continue to live and be paid in the foreign country while coming to the U.S. on a temporary or sporadic basis to assist when needed. Oftentimes, a company will request a 3-year intermittent visa to allow a key employee to enter the U.S. as needed for multiple projects, such as year-end audits or software upgrades, while remaining as a full-time employee of the foreign hotel. If the employee spends less than 180 days per year in the U.S., most visa categories allow for indefinite extensions for these purposes.
Company Blanket Program
Hotel groups with multiple international locations may want to consider the Blanket L-1 petition, which offers a streamlined and efficient solution for transferring executives or managers to the U.S. Instead of preparing and filing individual petitions for each employee, eligible companies can obtain a blanket approval of the corporate relationship of multiple properties that allows qualified staff to apply directly at U.S. consulates. In the case of Canadian citizens, these individuals may apply at a U.S. port of entry. This border-based application process for Canadians eliminates the need for prior consular appointments and significantly reduces processing time, making it ideal for urgent or short-term task force deployments.
To qualify for an L-1 Blanket petition, a company must meet certain criteria, such as having 10 prior L-1 approvals in the past 12 months, $25 million in annual U.S. sales, or 1,000 U.S. employees. Once approved, the company can transfer foreign nationals between properties listed on its L-Blanket Entity List, avoiding the time-consuming documentation and adjudication required for individual petitions. This flexibility makes the Blanket L-1 program a powerful tool for hotels managing frequent cross-border staffing needs, allowing for rapid mobilization. Intermittent status is available for the L-visa, which is ideal for employees who rotate between properties or oversee multiple initiatives.
TN for Canadians or Mexicans
Under the United States-Mexico-Canada Agreement (USMCA), the TN visa allows qualified Canadian and Mexican professionals to work temporarily in the U.S. in designated occupations, including Hotel Manager and Accountant. Applicants must have a job offer from a U.S.-based employer and meet strict educational requirements, typically a bachelor’s degree in hotel or restaurant management or a diploma plus experience. Intermittent status is allowed for the TN visa category. While the visa category is the same, the application process differs significantly between Canadian and Mexican citizens. Canadian citizens benefit from a streamlined process and can apply directly at a U.S. port of entry or preclearance airport without needing to first obtain a visa from a consulate.
For first-time applicants, U.S. Customs and Border Protection (CBP) has designated 14 optimized ports of entry for TN visa processing. These locations are staffed with officers trained in TN adjudication, offering faster and more consistent processing. While Canadians may apply at any port of entry, using one of these optimized locations is strongly recommended to reduce the risk of delays or misinterpretation of eligibility. Some ports also require appointments or have limited processing hours, so applicants should check in advance.
Mexican citizens, on the other hand, must apply for a TN visa at a U.S. consulate in Mexico before entering the U.S. They cannot apply at a port of entry. Only certain consulates, specifically those in Mexico City, Guadalajara, and Ciudad Juárez, are authorized to process TN applications. For both Canadians and Mexicans, the TN visa is typically granted for up to three years and can be renewed indefinitely, provided the employment remains temporary in nature.
E-2 Treaty Investor Visas
For hotel companies with foreign ownership from a treaty country, the E-2 Treaty Investor Visa offers a valuable pathway for transferring executives or essential employees to the U.S. This visa is available only to nationals of countries that have a qualifying treaty with the United States, and the U.S. entity must be at least 50% owned by individuals or companies from that same treaty country. The E-2 is commonly used for hotel openings, expansions, or strategic initiatives where the foreign parent company has made a substantial investment in the U.S. operation. Intermittent status is available for the E-2 visa category.
Once the company is registered under the E-2 program with a U.S. consulate, it can more easily sponsor additional staff from the treaty country, streamlining future deployments. While not suitable for all international staffing scenarios, the E-2 visa is a powerful tool for long-term strategic staffing when the ownership and nationality requirements are met.
J-1
The J-1 Exchange Visitor Visa is ideal for structured training programs in hospitality. It is commonly used for internships or traineeships lasting 6-12 months in luxury hotels and resorts. Participants must be students, recent graduates, or professionals with hospitality experience. While not suitable for filling leadership roles, it’s a strong option for training-focused deployments.
E-3 for Australians
The E-3 visa is a strong option for Australian nationals assigned to task force roles in the U.S. hospitality industry. It is designed for specialty occupations, which often align with the responsibilities of task force staff, such as implementing operational strategies, conducting training, or overseeing system rollouts. It requires a job offer, an approved Labor Condition Application (LCA), and a bachelor’s degree related to the job or equivalent experience. It is valid for up to two years and renewable indefinitely, making it ideal for short-to medium-term deployments.
Untimely or Difficult Visa Options for Task Force
While some visa categories offer flexibility and speed, others present significant challenges for hotels trying to deploy task force staff across borders. While useful in other circumstances, these classifications often take more time to execute.
Non-Canadian Individual L’s
The L-1 visa is commonly used to transfer executives or specialized employees from a foreign office to a U.S. location. For companies that do not have an approved L-Blanket certification, their Canadian employees can still process “individual” L visa requests at a U.S. border crossing. However, for non-Canadian nationals, the process can be burdensome. In addition to showing that both the current and proposed positions include managerial or specialized duties like an L-1A Blanket petition, an individual L petition requires extensive documentation to prove that the foreign hotel and the U.S. hotel share a “corporate relationship” and that they are both “doing business.”
Collecting this evidence can take several weeks for the Hotel to acquire. Additionally, in recent years, increased scrutiny from United States Citizenship and Immigration Services (USCIS) has led to longer processing times and more frequent denials. For urgent or short-term task force needs, the L-1 visa may not be feasible unless the company has a blanket petition already in place.
E Visa for Non-Registered Companies
For hotel companies that are not yet registered under the E-2 Treaty Investor program, sponsoring task force staff through this visa category can be challenging. The E-2 visa requires that the U.S. entity be at least 50% owned by nationals of a treaty country and that a substantial investment has been made in the U.S. business. However, before any employees can be sponsored, the company must first go through a formal registration process with a U.S. consulate. This process involves submitting detailed documentation about the ownership structure, investment amount, and operational plans.
Without this registration, even qualified employees from the treaty country cannot be issued E-2 visas. Additionally, if the company’s registration lapses due to inactivity or lack of current E-2 visa holders, the process must be restarted. For hotel groups seeking to deploy task force staff quickly, the lack of registration can create significant delays, making the E-2 visa impractical.
H-1B
The H-1B visa, while well-known, is rarely suitable for task force staffing in hospitality. It is designed for specialty occupations requiring a bachelor’s degree or higher, and hospitality roles often struggle to meet this threshold. The visa is subject to an annual lottery system, with applications submitted in April for October start dates, making it impractical for urgent staffing needs. Furthermore, the cost of filing a new H-1B petition has risen dramatically, with fees now exceeding $100,000 for H-1B petitions filed on or after September 2025. These financial and timing constraints, combined with strict job classification requirements, make the H-1B a poor choice for flexible, short-term international staffing in the hotel industry.
Conclusion
Task force staffing is an essential strategy for hotels managing changing needs across international properties. Whether addressing temporary vacancies, supporting growth initiatives, or overseeing audits and training, the ability to mobilize experienced personnel quickly and compliantly is crucial. However, crossing borders introduces a complex layer of legal considerations that cannot be overlooked. From distinguishing business visitor activities to identifying the appropriate work authorization or visa, each decision carries implications for compliance, timing, and risk.
By understanding the nuances of visa categories, from efficient options like Blanket L-1s, TNs, and E-3s to more challenging paths like H-1Bs and non-blanket L-1s, hotel leaders can make informed choices that protect both their workforce and their brand. With the right strategy and awareness, international task force staffing can remain a powerful tool for international hotel portfolios.
Ms. CallThis article was co-authored by Megan Call. Ms. Call is a dedicated immigration attorney at Grzeca Law Group who concentrates her practice on business immigration matters. She works closely with employers to navigate the complexities of the U.S. immigration system, providing strategic guidance from the initial transfer of foreign talent through to the attainment of permanent residence. She earned both her Bachelor of Arts in 2020 and her Juris Doctor in 2023 from the University of Wisconsin-Madison. She is admitted to practice law in Wisconsin and is an active member of the Wisconsin State Bar. Ms. Call is passionate about helping businesses grow through thoughtful immigration planning and compliance.
Mr. Grzeca
Jerome Grzeca, Managing Partner of Grzeca Law Group, S.C., has practiced business immigration law for thirty years in both Washington, D.C. and Milwaukee, Wisconsin. He has extensive experience providing legal services to the international business community for the hire and transfer of key personnel around the world. He has represented clients in the hospitality, healthcare, biotechnology, mining, energy, information technology, automotive, transportation logistics, architectural, professional services, academia and manufacturing industries, among others. Mr. Grzeca most recently served as Chair of AILA's DOS Liaison Committee. He is a past Director on the AILA Board of Governors and Chair of the Taskforce on Affiliate Programs (2009); Vice Chair of the DOS Liaison Committee (2009-2010); Executive Director Search Committee (2009); Department of State Liaison Committee (2007-2008); USCIS National Benefits Policy Liaison Committee (2005-2007); Chair of the Wisconsin Advocacy Committee (2005-present); Chair of the Nebraska Service Center (NSC) Liaison Committee (2004-2006); Wisconsin Chapter Chair and Chair of the Milwaukee Bar Association (Immigration and Nationality Section) (2001-2003). He is a seasoned speaker and author of a variety of topics relating to business immigration law, and has served on more than fifty professional panels, webinars and round-table discussions for businesses needing expertise in immigration matters.
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