Immigration Consultant Services Dubai Abu Dhabi

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2 3 ABOUT STEP GLOBAL A Message From the Editor ................................................................. 6 TABLE OF CONTENTS A Closer Look .................................................................................... 8-11 Canada - Provincial Entrepreneur Programs ............................... 12 MFP Smart Citizenship ................................................................ 13-16 Canada Start-Up Program ................................................................ 17 Canada Owner-Operator Program ................................................. 18 Canada Quebec Immigrant Investor Program ............................. 19 TRUSTED IMMIGRATION CONSULTANTS IN DUBAI, ABU DHABI AND THE UAE Realize your dreams of a brighter future for you and your family by laying down the foundation today. Take the next step towards your dream life with help from the best immigration consultants in Dubai, Abu Dhabi and the UAE – STEP GLOBAL. UNITED STATES United States E-2 Investor Visa ........................................................ 21 Bypassing U.S. Immigration Hurdles ........................................ 22-30 United States L-1 Visa ........................................................................ 31 United States EB-5 Immigrant Investor Program ........................ 32 Considerations for Selecting ...................................................... 34-37 CANADA SPOTLIGHT ON SUCCESS Is Your Boss an Immigrant? ........................................................ 38-40 WWW.STEPGLOBALGROUP.COM

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6 7 A M E S S A G E F R O M THE EDITOR s I look back on the past year and look forward to the year ahead, I am excited by so many aspects of the current immigration landscape. 2019 has brought about a wealth of changes to both American and Canadian immigration policy. We have seen various provincial changes to the Cana- dian Entrepreneur Programs. Most notably, Ontario took steps to decrease the provincial entrepreneur program investment amount to $200,000 CND outside the Greater Toronto Area (GTA) and $600,000 CND inside the GTA from $500,000 CND and $1 million CND respectively. As a Canadian who has grown up in Toronto, I personally look forward to welcoming new businesses and immigrant investors to the place I call home. The trend to extend open arms to new business and entrepreneurship into Canada is fur- thered by Canada’s Start-Up Program, which aims to attract innovative ideas into Canada as a new North American hub for technology. The biggest change to happen this year was the U.S. government deciding to continue operating the United States EB-5 Immigrant Investor Program, but finally at the higher price point of $900,000 USD in targeted employment areas and $1.8 million USD everywhere else. This is a change Congress has been discussing for years and comes with a host of con- troversy. Many regional centers have thrown their hands up, as new definitions of “targeted employment areas” and increased investment amounts threaten economic hardship on existing projects. Others see the changes as a good way to curb the ever-increasing number of applicants to the program. In 2019, India was the third country (behind China and Vietnam) to hit EB-5 retrogression whereby Indi- an nationals had surpassed the annual 700 per country green card quota, and all further applicants were pushed to the next year for visa issuance. This only further illustrates the marked increase in number of EB-5 applicants form 2008 until date. Although these huge changes are occurring, I don’t see North American immigration slowing down any- time soon. Canada and the U.S. still remain the most coveted of passports globally and it’s no secret why. With highly recognized health care systems, educational institutions producing a host of uber successful individuals worldwide, and a superior quality of living, the Americas truly still remain the land of opportunities. We have chosen to focus our 2020 edition of Smart Citizenship on North America, specifically for this rea- son. Learning about the various options available is the first step to reaching your Canadian and Ameri- can immigration goals. There truly is a path for everyone, and we welcome the opportunity to take this journey with you. Sincerely, Preeya Malik Managing Director A

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8 9 C A N A D A C A N A D A he approaching retirement of the baby boomer generation means that the business landscape is poised for a dramatic shift. According to the Canadian Federation of Indepen- dent Business, 47% of business owners intend to exit their business within the next 5 years, 8% within the next 12 months, and 39% within the next 1 to 5 years. Over $1.5 trillion of business assets could be transferred to a new generation of business owners over the next decade, up 50% from the last estimate in 2012. If these assets are not properly transferred, for example, businesses simply cease trading, and this would result in significant impact on jobs and economy overall. The problem for the baby boomers is that there are not enough local people wanting to buy their business. What is the nexus between business succession and the provincial nominee, entrepreneur, program? The provincial governments in Canada are actively looking for foreign investment and entrepreneurs, who are willing actively to invest and to start-up or to buy a locally established business. The mechanics of this process allow the foreign entrepreneur to enter Can- ada on a work permit and then convert to permanent resident status, subject to meeting mandatory criteria. The dependent family will be included in the entrepreneur’s application. Each province and territory in Canada has its own entrepreneur program and rules vary from one location to another. The availability of programs, flexible criteria, and appealing investment requirements, make these programs highly attractive to prospective immigrants with relevant business background. The assessment against the core criteria is made by each provincial government and then the final processing passes to the Immigration, Refugees and Citizenship Canada, the relevant federal agency, for the public interest criteria assessment (i.e. health and character). T CANADA A CLOSER LOOK INTO THE PROVINCIAL NOMINEE, ENTREPRENEUR, PROGRAM

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C A N A D A C A N A D A 10 11 The Provincial Nominee programs are actively looking for successful business people to immigrate and to run a business in their province. These immigrants will not qualify for permanent resident status on the basis of passive investments, but on the basis of hold- ing equity in a business and managing its operations. • Each province has its own requirements relat- ing to the assets held by the applicant and the minimum level of investment in the business in Canada (there will generally be an assessment about the equity in the applicant’s business in their own country) • The path to permanent residence starts with the applicant expressing interest in a province and submitting an application for nomination at the provincial level. The expression of interest application will take into account a few factors indicated below. In most instances, applicants are granted temporary entry to Canada with the right to work and they would subsequently apply for permanent resident status, on the basis of entering and managing their business • Applicants are assessed on the basis of net worth, business plans, professional experience, and adaptability. While speaking English or French in Canada is important, the threshold for the language ability is the lowest on the Canadian Lan- guage Benchmark scale (4 out of the maximum 10) • The applicant is required actively to participate in the management of the business on an ongoing and daily basis • The applicant is expected to have at least 2-3 years’ experience as business owner/senior manager • The business is expected to result in benefits to the local community most commonly met by creating/maintaining employment for Canadian citizens or permanent residents of Canada • An exploratory visit to the selected province is advisable in all cases • Having adequate resources to establish a life and enter a business: the financial thresholds vary, from a maximum of CAD$800,000 net worth in Greater Toronto Area (Ontario) to lesser net worth requirement in Saskatchewan and Manitoba • Financial commitment to the business in Canada also varies from CAD$600,000 to CAD$200,000 in Greater Toronto Area (Ontario) to figures such as CAD$150,000 in Manitoba • If purchasing an existing business, the business must have been in existence for the past 5 years • Most programs allow for a work permit and grant of permanent resident status after two years, on the provision that the applicant enters Canada and is managing the business. The large numbers of existing businesses for sale in Canada, can be a good solution for people looking to transition into a new business environment. There are lesser risks involved in purchasing a locally established business (less start-up costs, seller remains on board for mentorship, financials are in order, the business is profitable) as opposed to starting a new business. Our concern is not just helping clients enter Canada, but helping them successfully settle and build a life in Canada. THE ENTREPRENEURS AND THE PROVINCIAL NOMINEE PROGRAMS – THE PROCESS We partner with various stakeholders to ensure that the local seller is matched with the right entrepreneur, thereby ensuring a smooth immigration and settlement process for the entrepreneur and his/her family. “ ” Cosmina is a Senior Manager at Fragomen, responsible for Canadian temporary and permanent residence immigration matters. She also leads the firm’s private client practice in Toronto. Cosmina supports clients with various Canadian work permit and entry visa requirements, including Labour Market impact assessments, electronic travel authori- zations, inadmissibility applications and permanent residence filings. She also assists clients in understand- ing their obligations with the immigration programs and represents them in employer compliance reviews, audits and inspections. She is experienced in representing a mix of major global businesses and smaller, locally based, businesses across various industries, assisting them in imple- menting cost-effective relocation strategies, as well as planning the foreign population. Cosmina regularly interacts with Immigration, Refu- gees and Citizenship Canada’s domestic case processing centers, the Canada Border Services Agencies at various ports of entry, as well as Canadian Consulates and Canadian Embassies worldwide, and provides feedback to authorities on policy and procedural matters as part of the Toronto office’s government relations team. Cosmina has authored numerous articles and participates in the firm’s client mute calls. Beginning in April 2016 to the present, Cosmina has volunteered as a Mentor as part of the Women Mo- bilizing Women program in Toronto, Ontario. She also participates in the Toronto office’s initiatives working closely with the Herbie Fund to provide the immigration services needed to bring children from around the world to The Hospital for Sick Children, also known as SickKids. These services have been provided since 2011. From 2004 to 2008, Cosmina volunteered at the Fairview Mall Legal Clinic in Toronto, Ontario, where she was primarily involved in provincial offences and Canadian immigration matters. Cosmina speaks English, French and Romanian. COSMINA MORARIU Osgoode Hall Law School | LL.M., 2018 Nottingham (Trent) University | Bachelor of Law, 2014, honors Seneca College | Immigration Practitioner Certificate, 2010 University “Lucian Blaga” Faculty of Law, Sibiu (Romania), 2001, honors

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C A N A D A C A N A D A 12 13 PROGRAM SUMMARY PROVINCIAL ENTREPRENEUR PROGRAMS INVESTMENT AMOUNT CND $150,000 TO $600,000 (VARIES BY PROVINCE) INVESTMENT TYPE Business Venture SPOUSE Yes CHILDREN Yes (under 22 years of age) PARENTS No (can be sponsored after Citizenship) PROCESSING TIME Varies by Province PHYSICAL RESIDENCY REQUIREMENTS 3 out of 5 years LENGTH OF STATUS RECEIVED 2 to 5 years PERMANENT RESIDENCY Varies by Province CITIZENSHIP 5 years of permanent residency SPECIFIC PROGRAM REQUIREMENTS Minimum Net Worth Requirements Some provinces may only be open to specific industries NATIONALITY DISQUALIFICATIONS No DUAL CITIZENSHIP Yes hrough migration to Canada you will be free to live perma- nently in a country which has consistently been rated by the UN as the world’s best country to live in. Fur- thermore, students in Canadian schools performed better in mathematics, read- ing and science than students from any other English speaking country. Final- ly, Canada enjoys universal healthcare where medical treatment is publicly (tax-payer) funded. For those who also want access to other countries, citizenship in Canada will allow for access to the United States via the NAFTA Agree- ment, as well as visa free or visa on arrival travel to over 172 countries worldwide. CANADA T MFP SMART CITIZENSHIP mart Citizenship engages people in processes that respect and develop local knowledge. Well grounded processes re-prioritize our needs and interests as knowledge is gathered and developed. Smart Citizenship is intended to improve a person’s quality of life. The primary focuses of this discussion is on business and specifically, entrepreneurship. The narrative of cause and effect that many believe drives business and finance also drives our economic status. As your own best salesperson, your focus will be on your own cause and effect journey, management and transformation. An inherent component of this focus will be toward professional and social opportunities that offer a platform for networking experiences, the exchange of ideas and spawning international business deals. International business deals may be driven by a desire to develop a local market or the desire to physi- cally move and adapt to a new market. The possibility of a successful outcome will be ad- vanced by gauging the market and determining the best fit businesses for the target market as well as the best fit for the Smart Citizen. Research, analysis and due diligence of business opportunities and oneself are critical to success throughout this process. Smart Citizenship leads to personal consumption choices and the individual autonomy to make those choices. Choice and autonomy come with costs, re- sponsibilities and the need for self awareness and market awareness. Business offerings need to recog- nize pre-determined targets and how to fulfill pre- set deliverables. S

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C A N A D A C A N A D A 14 15 The most informed decisions leverage research, analysis and due diligence about the target destination and opportunities therein as well as taking an unbi- ased introspective analysis. The Smart Citizen needs to understand the deliverables, the outputs and how to successfully attain both. Applying research, analysis and due diligence to the Smart Citizen demands an in depth look at five key elements: Skills, Experience, Passions, Desired Life- style and Finances. As a franchise consultant, it is my pleasure to em- brace the qualities of Smart Citizenship into well informed business decisions as it pertains to applying for, and investing in, a franchise opportunity. The ultimate objective is not the consummation of a cursory search for the most affordable opportunity or the latest trend. The goal is to translate the assets of a Smart Citizen into a viable, satisfying opportunity. Anybody can succeed in business, with the right opportunity. The goal of our combined effort, is to find the right opportunity for you. Migrating to a new environment demands patience and focus. Partnering with an immigration consultant with strategic partnerships can set you up for long term success with business opportunities. Some of these opportunities may be unknown to you at the start of your journey. A Smart Citizen understands the need for a strategic partner on the ground in their new environment; someone who understands the local market and has the capacity and will to help them find the best fit with a commitment to effective research, analysis and due diligence. If your migration process includes considering business ownership options, then I suggest the training, operating systems, on-going support and marketing of franchises. Looking beyond the horizon of the most common brands will reveal many opportunities with a history of strong performance. As you are aware, the issue of ageism is gaining more awareness of late. The best way to combat the risks of ageism in the workplace, is to own the workplace. Franchises afford you the opportunity to help people develop and grow on a daily basis. As a business owner, you have the opportunity to impact people’s lives, everyday. At My Franchise Partners, we apply the fundamentals of Smart Citizenship to help ensure your success. For example, you are not asked to pay franchise fees until your immigration status is approved. Does the location make sense for you and your family. You will benefit from our connections to local legal, accounting, marketing and real estate professionals. We develop strategic partnerships with like mind- ed companies locally and abroad, such as the Step Global Group. Through the important research and analysis of your personal attributes and goals we will discuss various options that could be a good fit for you. You will be pushed to transcend your comfort zone, to understand and explore the transfer of your skills and experience to new endeavours. Early in the process, you will be asked to complete a Business Owner Profile. This profile will help us understand your tendencies, attributes and potential as a business owner and manager. The Business Owner Profile will help identify if you are more oriented toward established schedules and plans, if you are better suited to the freedom of a more flexible schedule or something in between. We apply the fundamentals of Smart Citizenship to help ensure your success. “ ” We will discuss your ability to delegate and lead a team just as we will also delve into your need for managing a personal schedule with children or dependent adults. As a single parent for 18 years, I fully understand the magnitude of managing multiple schedules and expectations. A franchisor’s management team will be considered for their strengths and weaknesses as well as their proclivity to working with certain types of candidates and of course the nuances of the local market that you are considering. Item 7 of the FDD details the expected costs for the initial 90 days of your franchise. Unless you are buy- ing a successful re-sale franchise, it is improbable that you will generate positive cash flow right away. Together, we will work through an in-depth analysis of Item 7. We will walk hand in hand through the research, analysis, due diligence, application and FDD review, Discovery Day, training, grand opening and beyond. Everybody can succeed in business with the right opportunity. Together, we will find the right fit for you. Leading Opportunities. In-Depth Consultation. Forward Thinking Analysis. No Fees. Andrew Hoffman CP CMA FAAPM President - My Franchise Partners The best way to combat the risks of ageism in the workplace, is to own the workplace. “ ”

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C A N A D A C A N A D A 16 17 CPA CMA CIPM FAAPM PROGRAM SUMMARY START-UP PROGRAM INVESTMENT AMOUNT CND $150 000 (RECOMMENDED) INVESTMENT TYPE Business Venture INVESTMENT TERM Yes SPOUSE AND CHILDREN Yes (under 22 years of age) PARENTS No (can be sponsored after Citizenship) PROCESSING TIME 12 to 16 months PHYSICAL RESIDENCY REQUIREMENTS 2 out of 5 years to maintain PR 3 out of 5 years for citizenship LENGTH OF STATUS RECEIVED Permanent status PERMANENT RESIDENCY Immediately CITIZENSHIP 3 out of 5 years of permanent residency SPECIFIC PROGRAM REQUIREMENTS Letter of support from qualified institution Innovative business idea Detailed business plan NATIONALITY DISQUALIFICATIONS No DUAL CITIZENSHIP Yes EDUCATION IN CANADA • free public school education • (Preschool through High School) • top rated universities • tuition rates at 1/3 of international student rates • highest rated English curriculum worldwide CANADA Andrew Hoffman is a single parent of one son, currently in University which motivates him on a daily basis. He has over 30 years of success with business development as well as financial and operations management on the global stage. He has managed budgets up to $85M for manufacturing, co-packing, and sales and consulting organizations with single or multi-locations and/or international commerce. An- drew has also had a direct hand in operation strategies which grew revenue by 10%+ for multiple suc- cessive years in an industry with traditionally annual growth of only 3%. Andrew takes pride in helping investors make the transition from Employee to Empowerment with in- depth research, analysis and due diligence of franchise opportunities. He is able to provide guidance through the roll-out and business development phases of a business launch. Not only does Andrew deliver education and training webinars for franchise industry professionals, but he also coaches entrepreneur owners of independent businesses. The management of hyper-growth and start-up opportunities and aligning cross functional finance is another area of Andrew’s expertise, which has given him the specialization and skill to provide results for turnaround situations for both start-ups and businesses in bankruptcy. ANDREW HOFFMAN

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Migration is an expression of the human aspiration for dignity, safety and a better future. It is part of the social fabric, part of our very make-up as a human family. “ ” Ban Ki Moon BYPASSING U.S. IMMIGRATION HURDLES 22 23 eople are enticed to migrate to the United States as the Great America is the apothe- osis of land of opportunities with an abun- dance of natural resources, better living standard, and social and economic security. Migra- tion to the Unites States begun as early as the 16th Century due to which the land flourished as it was fed and nourished by hordes of people appertain- ing to different cultures, ethnicities and civilisations thus making it today’s Great America. The migration of people started with the first European settlements around 1600. During this early phase of exploration and settlement, British and other Europeans settled primarily on the east coast because of the easy and direct accessibility to East coast from Europe. Since the early times the United States has witnessed suc- cessive waves of immigration, predominantly from Europe initially and subsequently from Asia, Latin America and Africa. Migration to economically and politically stable nations like the United States has enabled individuals and families to secure the highest levels of life satisfaction, financial security, personal safety and health. A wealth of natural resources, aero-space, IT, tourism, real estate, hospitality, infrastructure and automobile manufacturing industries provide ample of business, investment and employment opportunities to prospective immigrants in this multi- cultural land. The most straight-forward and the simplest way to immigrate to U.S. is by investing into a new business enterprise, such as a large hotel or residential project under the EB-5 Immigrant Investor Visa Program and become a lawful permanent resident or “green card” holder. However, this particular EB-5 Investor Visa category is now experiencing allocation delays for certain countries. As the EB-5 visa has a strict cap of 7%, only 700 out of 10,000 visas annually can be allocated to one particular country and not more than that. Consequently, the growing popularity of the program is leading to halting backlogs for the most popular countries. The EB-5 delays are mostly P affecting the Chinese applicants with a wait time currently up to 14 years. Chinese being the custom- ary investors have always eyed upon such immigration by investment options across the world and have historically prevailed over the applicants from other countries in such programs, often meeting or exceeding quotas allocated to Chinese applicants. However, even for Indian and Vietnamese applicants the waiting time is tentatively between 2 to 5 years, respectively. Other countries are experiencing average waiting times, as they are still far under the 7% annual threshold. In addition to these delays, there have been recent amendments introduced by the U.S. congress in the EB-5 Immigrant Investor Visa Program with effect from November 21st 2019, marking the first significant revision of the program’s regulations since 1993. Under these amendments and as per the new regulations, the standard investment level has increased from $1 million to $1.8 million and the minimum investment amount in a TEA (Targeted Employment Area) has increased from $500,000 to $900,000. Also, as per the new regulations, the minimum investment amounts will automatically adjust for inflation every five years, thus making the program pricier in the coming years. Certainly, these amendments have pushed this popular program out of affordabil- ity reach of many, thus a stumbling block for such prospective investors. Alternatively, in such a dispiriting scenario, there are ways to ease the pain of retrogression and notably high investment under the EB-5 Immigrant Investor Visa Program, one of which is by acquiring non-immigrant visas and entering the U.S. as a business investor. Assuredly, the best visa category under this option is the E-2 Investor visa. The E-2 Investor visa grants residency status to investors, spouses, and minor children. However, the E-2 Investor visa is only obtainable by a main applicant who is a national of a country which is an E-2 treaty signatory with the United States. There are around 78 E-2 treaty countries. But what does one do who is not a national of the lim- ited E-2 treaty list? Can they still access the E-2 visa process? The answer is yes. Out of this bulky list only two E-2 treaty countries allow an investor to speedily acquire citizenship and open the door to the E-2 visa: the Caribbean island nation of Grenada and Turkey. The citizenship acquiring process in these two countries is very straight- forward and ranges from 3 to 6 months. Thus such a short timeline and convenient process allow investors to acquire a Grenadian or Turkish passport within few months and then enter the U.S. on Treaty Investor status, under which spouses can obtain sep- arate employment, and children can be part of the education system of the United States. U N I T E D S T A T E S U N I T E D S T A T E S

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INTRODUCTION TO GRENADA CITIZENSHIP BY INVESTMENT PROGRAM E-2 TREATY COUNTRY - GRENADA NTF DONATION OP- TION INDIVIDUAL APPLICANT MAIN APPLI- CANT + SPOUSE FAMILY OF FOUR FAMILY MEMBERS FAMILY OVER FOUR FAMILY MEMBERS REQUIRED CONTRIBUTION AMOUNT USD 150,000 USD 200,000 USD 200,000 USD 200,000 plus USD 25,000 per additional dependant after the third dependant APPLICATION FEE USD 1,500 USD 1,500 (per person) USD 1,500 (per person) USD 1,500 (per person) DUE DILIGENCE FEE USD 5,000 USD 5,000 (per person) * Dependent child 0 – 16 nil * Dependent child 17 – 25 USD 5,000 PROCESSING FEE USD 1,500 USD 1,500 (per person) USD 1,500 per person aged 18 and over, USD 500 for persons under 18 USD 1,500 per person aged 18 and over, USD 500 for persons under 18 REAL STATE OPTION SINGLE APPLICANT MAIN APPLI- CANT + SPOUSE FAMILY OF FOUR FAMILY MEMBERS FAMILY OVER FOUR FAMILY MEMBERS REQUIRED CONTRIBUTION AMOUNT USD 220,000 USD 220,000 USD 220,000 USD 220,000 GOVERNMENT FEE USD 50,000 USD 50,000 USD 50,000 USD 50,000 and USD 25,000 per additional dependant after the third dependant APPLICATION FEE USD 1,500 USD 1,500 (per person) USD 1,500 (per person) USD 1,500 (per person) DUE DILIGENCE FEE USD 5,000 USD 5,000 (per person) * Dependent child 0 – 16 nil * Dependent child 17 – 25 USD 5,000 PROCESSING FEE USD 1,500 USD 1,500 (per person) USD 1,500 per person aged 18 and over, USD 500 for persons under 18 USD 1,500 per person aged 18 and over, USD 500 for persons under 18 REAL ESTATE OPTION 24 25 he Caribbean island nation of Grenada is a sovereign state in the West Indies. Grena- da, known as the “Island of Spice” due to its production of nutmeg and mace crops, has a vivacious rich culture and history, with English as the country’s official language. Being situated along the tropics Grenada is situated between the Caribbean Sea and Atlantic Ocean, north of Venezu- ela and has a tropical wet climate with an average annual temperature of 28°C which makes it one of the most preferred destinations to visit and stay. The country is ardently dedicated towards growth and development, and is building up a robust educational, financial and medical infrastructure to align with its emerging economic and demographic needs. Grenada is an excellent choice for investment – providing applicants with the opportunity to participate in its fast-growing tourism sector and diversifying economy. This country is the ideal location for families, granting access to world-famous educational institutions such as St George’s University and to com- prehensive healthcare units. The Grenada CBI programme provides second citizenship in Grenada and a passport to investors of- fering visa-free travel to over 143 countries including the UK, EU Schengen countries and China. Grenada also offers access for its citizens to the United States E2 treaty investor visa. Applicants must invest either $150,000 USD as a donation towards National Trans- formation Fund (NTF) or $350,000 USD in a government approved real estate project (can be reduced to $220,000 USD for associated investors). The investment shall remain in place for at least 5 years. The program has been a great success over the years due to its relatively lower amount of investment and its strong due diligence checks on applicants within 60 business days of the country receiving a complet- ed application – the time in which an applicant can expect his application to be processed by the T the Citizenship by Investment Committee. Its eco- nomical approach and fast processing times have made it affordable and feasible for most of the potential investors, as with one investment, a family can secure citizenship for the principal investor, that investor’s spouse, children under the age of 30, and parents over the age of 55. There is no requirement to visit Grenada during the process and it is important to note that Grenada has no residency requirement for investors. There is presently no restriction or embargo on any nationality from applying. With the Grenadian passport in hand, an investor unlocks the ability to apply for an E-2 visa. DONATION OPTION U N I T E D S T A T E S U N I T E D S T A T E S

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26 27 INTRODUCTION TO TURKEY CITIZENSHIP BY INVESTMENT PROGRAM E-2 TREATY COUNTRY - TURKEY urkey is a transcontinental country located at the crossroads of Europe and Asia. Tur- key has emerged as one of the key players in the world economic and political order due to its strategically important geographical location which provides it leverage. Turkey is bordered by Greece, Bulgaria and Georgia to its north, Iran to its east and Iraq and Syria to its southeast. Turkey has a blend of different cultures and a diverse climate and landscape. The present Turkish government is staunchly devot- ed towards transforming its national economy into a high-return robust economy and it is focused on bringing grassroot level reforms in the economy both at the micro and macro levels. It is constantly making earnest efforts to ensure a favourable environment for new entrepreneurs in order to help them con- veniently and efficiently start their new businesses. Turkey has a high number of English-speaking skilled young professionals which immensely contribute to the economy by being the primary working force and help in improving the average age of demographic. A large number of multinational corporations’ view Turkey as the perfect place to open a head, or regional office, as its strategic location, excellent logistics, and favourable tax policies, enable them to access a regional market of over 500 million people. In order to further boost the flow of foreign investments in the country, in September 2018, the Turkish government introduced another set of major reforms in its immigration policy which considerably reduced the minimum threshold investment amount required to be invested under its popular Citizenship by Investment Program. The main investment options under the Turkish CBI program are: • a minimum investment of $250,000 or more shall be made in a real estate property for the period of at least three years, or; T • a minimum of $500,000 or more shall be depos- ited into a Turkish bank account at least for the period of 3 years, or; • a minimum of $500,000 or more shall be invested into a Real Estate Investment Trust (REIT), for at least 3 years, or; • purchase $500,000, or equivalent of government bonds, and hold onto for at least 3 years. The real estate option continues to prove the most popular as the investment amount is significantly lower than that of the other investment options, and investors would like a tangible asset which will ap- preciate over time. A Turkish passport allows visa free travel (or visa on arrival) to 114 countries across the world and makes one eligible to apply for an E-2 visa. INTRODUCTION TO THE E-2 VISA nce a non-treaty national obtains a Turk- ish or Grenadian passport, this will automatically provide eligibility to apply for the E-2 visa status within the United States. The E-2 Investor Visa enables an individual to reside and conduct business within the United States based on an investment he will be controlling, while inside the United States. The E-2 visa is active for three months to five years (depending on the country of origin) and can be extended indefinitely. The E-2 visa is one of the most popular visas in the U.S. immigration system as its multifaceted dynamic enactment is conducive to providing a manifold of options for residency, investment and business to the individual along with his dependents. The program is a non-immigrant classification. This means that the visa on its own will not lead to permanent residency in the United States. To obtain permanent residency, an individual must petition under another category at some point in time (such as an EB-5 or and EB-1C). O U N I T E D S T A T E S U N I T E D S T A T E S

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28 29 In order to obtain an E-2 Investor Visa, applicants must make a “significant investment” into a US business. Significant, meaning at least a 50% interest and the business investment can be as little as $150,000 into any nature of a legal business, including franchises. Under the E-2, the investor needs to make a “substantial” investment. The minimum investment amount is not clearly defined in the visa rules and regulations but it is presumed that the minimum investment amount is utterly dependent upon the nature and the scale of the venture to be created and the investment needs to be in proportion to the nature and scale of the business. Different businesses require different range of initial investment capital. For example, small scale Start-ups like a consultancy, being at the nascent stage requires a lesser investment amount which shall be enough to cover its ex- penses and cost of running the business during the incubation period. An investment for a larger business venture, such as an automobile manufacturing plant, will be probably in the millions. Many investors find investing into a franchise as the most viable option. Due to the well-defined and already executed business plan one can easily perceive the prospective success chances of the business. A franchise is a well-defined prototype emphasising on defined minimum investment and hiring plans, thus giving investor the ability to take leverage of a well-established brand chain with ubiquitous good- will across the country or continent. In addition, a franchise offers the independence of small business ownership by the benefits of a big business network with relatively higher success rates than start-up businesses. Processing times are much shorter in E-2 as com- pared to EB-5. This is one of the main reasons that applicants with business or professional background often consider E-2 as a more viable option than EB- 5, as it gives you a chance to regulate your own investment and execute your investment plans within months of applying rather than waiting in long queues for entry into the United States. CONDITIONS FOR OBTAINING AN E-2 VISA The E-2 visa is only obtainable by the national of the country which is E-2 treaty signatory with United States. The main applicant shall be a citizen of one of the countries which has signed the E-2 treaty with United States. There are around 78 E-2 treaty countries. INVESTOR SHALL BE A CITIZEN OF ONE OF THE E-2 TREATY SIGNATORY COUNTRIES 01 Capital, including funds and other assets, shall be at commercial risk with the objective of generating profit. Investment in business can be in varied modes. For example, you may establish a new business venture, purchase a pre-existing business or invest in a joint-venture. Either way, you must demonstrate that the capital you are investing is substantial. No minimum capital requirement is imposed. SUBSTANTIAL INVESTMENT SHALL BE MADE IN A NEW OR EXISTING BUSINESS 02 The investment must be in a business that is allowed or permitted under the law of land. The business must be a real, active commercial undertaking capable of producing goods or services for the purpose of accruing profit. The business shall be capable of generating enough income to provide a minimal living for the investor and his family or which makes a significant economic contribution. THE INVESTMENT SHALL BE INTO A LEGAL BUSINESS 03 It is crucial to demonstrate that the capital invested shall be irrevocably committed to the enterprise and subject to partial or total loss in the event that the business fails. The funds which you invest must also be your own. The invested funds must be substantial enough vis-a-vis the total cost of either purchasing an established enterprise or creating the type of enterprise you are considering. To be able to obtain an E-2 Visa, you must show a definite and legitimate path of the source of capital you are investing. THE FUNDS FOR INVESTMENT MUST BE ALREADY IN POSSESSION OF THE INVES- TOR AND THE FUNDS MUST DERIVE FROM A LEGITIMATE SOURCE OF INCOME 04 The investor must enter the United States with a determination to develop and direct the investment enterprise. The managerial role of the investor must be illustrated by showing at least 50% ownership of the enterprise or possession of operational control through a managerial position. ACTIVE INVOLVEMENT IN THE MANAGEMENT OF THE BUSINESS 05 http://www.stepglobalgroup.com/immigration/ https://www.uscis.gov/working-united-states/temporary-workers/e-2-treaty-investors https://www.cbi.gov.gd/grenada-citizenship/benefits/ https://www.invest.gov.tr/en/investmentguide/pages/acquiring-property-and-citizenship.aspx U N I T E D S T A T E S U N I T E D S T A T E S

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30 31 Albania Slovak Republic Trinidad & Tobago Argentina Croatia Tunisia Armenia Czech Republic Kazakhstan Australia Denmark (excluding Greenland) South Korea Austria Ecuador Kosovo Azerbaijan Egypt Kyrgyzstan Bahrain Estonia Latvia Bangladesh Ethiopia Liberia Belgium Finland Lithuania Bolivia France Luxembourg Bosnia and Herzegovina Georgia Macedonia Bulgaria Germany Mexico Cameroon Grenada Moldova Canada Honduras Mongolia Chile Iran Montenegro China (Taiwan) Ireland Morocco Colombia Italy Netherlands Congo Jamaica Norway Costa Rica Japan Oman Paraguay Jordan Pakistan Philippines Slovenia Panama Poland Spain Turkey Romania Sri Lanka Ukraine Serbia Suriname United Kingdom Senegal Sweden Yugoslavia Singapore Togo Deepanshu is a licensed lawyer and Head of Legal at Step Global. He obtained his law degree from the University of Delhi, India. Along with legal he also has a Journalism and Communications background. He is a Post Graduate in Business Journalism and Corpo- rate Communication from University of Delhi, India with a graduation in Journalism and Mass Communi- cation from GGS Indraprastha University, Delhi, India. He has practiced as an advocate and worked in different corporate verticals by blending his congenial combination of varied and high educational qualifi- cation and specialized work experience. Deepanshu now specializes in global investment immigration, with a focus on business and entrepreneur immigration programs. He has represent- ed Step Global by speaking at various international immigration forms. Deepanshu’s integration of legal acumen and corporate communications background has equipped him to provide in-depth analysis of immigration law of different countries, Investment agreements, PPMs and other investment related documents’ provisions to the clients, including compliance with statutory framework. His specialized skills set thereby enables him to deliver principal market-oriented results. DEEPANSHU CHOUDHRY LL.B | Bachelors of Law | University of Delhi/, Delhi, India Post Grad. | Business Journalism & Corp. Communication | University of Delhi, Delhi, India Seneca College | Immigration Practitioner Certificate, 2010 BJ(MC) | Bachelors of Journalism and Mass Communication | VIPS, GGSIPU University, Delhi, India Legal Manager/ Step Global U N I T E D S T A T E S U N I T E D S T A T E S CURRENT TREATY COUNTRIES

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36 37 FACTORS FOR SELECTING/STARTING A U.S. BUSINESS There are many foreign nationals who are interested in lending their professional and business acumen to start a business in the United States but are not yet sure of what type of business to establish or are hesitant to start up their own. These foreign nationals may consider a franchise business where the foreign national can rely on the franchisor’s business model, and recognizable brands and products to increase likelihood of success. The foreign national – taking on the role of both franchisee and executive – will own and have equity in the franchise business and can rely on the franchisor to assist with operating the business, including hiring employees. This type of arrangement then allows foreign nationals to invest in and own multiple franchises, and ideally multiple franchises will lead to increased financial returns for the foreign nationals. Even though the foreign national is not required to work in the actual franchise store day-to-day, the foreign national will be working on the overall franchise business by making executive-level strategic and growth decisions in further- ance of developing and, in many cases, expanding their franchise business. For those considering selecting a franchise in the U.S., here are some important factors to consider before a final decision is made. Not all franchises are created equal. Today’s popular or trendy dessert concept may be tomorrow’s empty space for lease. Although every entrepreneur or company understands risk is inherent in business, the differ- ence is normally your family doesn’t have to leave a country if a business fails. Thus, similar to EB-5, a smart investment or decision is one that also minimizes as many risks as possible. Ideally the franchise you’ve selected is not only successful, but has shown that it is stable and battle-tested to withstand both history and fickle consumer tastes. Look for a business that has shown it can survive the love (and attacks) of Yelp! and Tripadvisor as well as rollercoaster economic cycles. STABLE, PROVEN FRANCHISE BUSINESS: As important as the underlying franchise business is, it’s arguably even more important to consider whether you are entering into a deal directly with the master franchisor or parent company, or simply a franchisee or other third-party middleman. They will ultimately be your partner after all and one that you may need to rely on to help manage or operate your U.S. business, meet your immigration goals, and if you so choose, provide a viable exit strategy in the future. PARENT COMPANY VERSUS FRANCHISEE: The L-1A and EB-1C visa categories for multinational executives or managers is a two-step process towards United States’ legal permanent residence, also called a “green card”, and is a viable alternative route for many foreign nationals. 1 2 U N I T E D S T A T E S s the current political climate, visa backlogs, and general immigration uncertain- ties continue to prevent talented and skilled foreign nationals from entering the United States and obtaining a green card, foreign nationals, particularly from Asia are in search of other lawful avenues to move to the United States. For example, Indian-nationals who wish to pursue the H-1B Specialty Occupation visa are looking at a minimum wait time of 20 years before they can apply for a green card and officially settle down in the United States. Chinese-nationals who once upon a time were the primary recipients of the EB-5 visa, are forced to wait approximately 14-16 years before they can apply for a conditional green card and settle in the United States. As such, investors and entrepreneurs from these countries are looking toward other avenues to move to the United States and achieve their business and immigration goals. And while the supply of immigrant visas has seemingly decreased, the demand to live, work, and educate children in the United States continues to increase. A BACKGROUND ON THE L-1/EB-1C PROGRAM CONSIDERATIONS FOR SELECTING AN L-1/EB-1C U.S. FRANCHISE BUSINESS January 6, 2020 By: Niral Patel, Esq. and Phuong Le, Esq. In light of having to search for other ways to immigrate to the United States, the L-1A/EB-1C visa categories have grained traction for well-qualified investors and entrepreneurs who A) have a foreign business and B) wish to open a new business in the United States or acquire an existing business. U N I T E D S T A T E S

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If we cannot now end our differences, at least we can help make the world safe for diversity. “ ” 38 39 Phuong Le is a Partner with David Hirson & Partners, LLP’s dedicated EB-5 practice group. He draws upon an extensive background advising parties on all sides of EB-5 transactions, including regional centers, project de- velopers, agents and investors. Prior to joining the firm, he was in-house counsel for a large Southern California EB-5 regional center and real estate developer. There, he managed over $500 million in EB-5 financing and guided the company to several milestones, including approvals for their first 100 I-829 petitions. His clients span the entire industry. He has successfully advised regional centers and businesses across the United States on over $1.5 billion in EB-5 deals, including commercial real estate developments, multifamily apartment buildings, hotels, medical office buildings and restaurant franchises. He also oversees the firm’s Vietnamese practice group and regularly travels to Vietnam where he works closely with the firm’s business partners, agents and investors. Finally, he also frequently shares his knowledge with the industry as a lecturer, author and as co-counsel/peer review for other EB-5 attorneys. PHUONG LE David Hirson & Partners LLP John F. Kennedy U N I T E D S T A T E S Similarly, you should understand if whoever you’re entrusting with your U.S. business has shown that they can successfully operate more than one location, whether it’s an operator, management company, or franchisee. If it’s their first time handling more than one location, beware. SUCCESSFUL, MULTI-UNIT OPERATOR?: Be wary of “business opportunities” looking for overseas financing that want you to put up 100 percent of the money but only give you half of the ownership. Just because it satisfies immigration requirements doesn’t mean it’s suitable for your business needs. BUSINESS VALUATIONS AND YOUR INVESTMENT: Once you entrust your U.S. business to a manager or management company, ongoing transparency and mon- itoring is key. Many a business fail because people trust a family friend or acquaintance with operating their business or decide to go into business with them without considering whether they are prepared to guide the business to fulfill their business plan –namely whether it can continue to grow and hire enough people to support an EB-1C green card. Moreover, it’s in your interest to find a business that will allow you to monitor how your business is doing regardless of where you are in the world, whether through professionally prepared reports or real-time tracking through point-of-sales systems that provide information about how much daily sales your business is generating. TRANSPARENCY & ACCOUNTABILITY: The best type of franchises will continue to offer their franchisees ongoing support and training once they come on board. While the above list presents several key concepts, the good news is that it is possible to find U.S. franchises/ businesses that meet the above criteria. Of course, the best option is always situation specific including one’s appetite (or tolerance) for risk. TRAINING AND SUPPORT FOR U.S. FRANCHISEE: 3 4 5 6 U N I T E D S T A T E S

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WORLD RENOWNED COMPANIES AND THEIR IMMIGRANT FOUNDERS 40 41 We often see families who are gaining migration for the benefit of their children, both for education and for future prospects. Families can be encouraged by the attraction of international students into the United States, which further fosters a sense of entrepreneurship. About 23% of immigrant founders first came to America as an international student. Companies such as Affirm, JetSmarter and Warby Parker were started by immigrants who first came to the U.S. as children, which gives families hope that the American Dream can come true. Outside of founders of companies, it is also a fact that immigrants have played a key role in the expansion of businesses by fulfilling important positions such as Chief Executive Officer and Chief Technology Officer. Credit to these extraordinary entrepreneurial minds cannot be given to just first-generation immigrants. Sec- ond-generation immigrants (children born to first-generation immigrants) have also done wonders for the U.S. economy and for history as a whole. Did you know that Apple’s founder Steve Jobs’s father was Abdul Fattah Jandali, a political migrant from Syria? Amazon’s founder Jeff Bezos is the son of a Cuban immigrant. These are again, two of the largest companies in history. Let’s explore some of the other companies which you know of and which were also started by immigrants: Founded by Elon Musk, a South African Immigrant. SpaceX and Tesla are responsible for a combination of 18,000 jobs. Co-founded by Jerry Yan, a Taiwanese immigrant. Yahoo brought in over $5 billion in revenue in 2017 alone. Founded by two German immigrants, Charles Pfizer and Charles Erhart. Pfizer employs 96,500 people. Everyone knows Google, co-founded by Russian immigrant, Sergy Brin. Google employs over 85,000 people and brought in over $110 billion in 2017. Is it true? Immigrants are almost twice as likely as native born Americans to become entrepreneurs? A study from the National Foundation for American Policy has stated that 55% of $1 billion startups in the United States had at least one immigrant founder. Nearly 30% of new companies in 2016 were started by immigrants. These companies are generating billions of dollars in revenue and also creating millions of jobs each year. Imagine what the country would lose by continuing to implement restrictive policies on immigrant and refugee entry into the U.S.! The companies we are talking about are not small. The collective value of 50 immigrant-founded companies is approximately $248 billion. Think Uber and E-bay, co-founded by Garrett Camp (Canadian Immigrant) and Pierre Omidyar (French immigrant) respectively. Not only have immigrants shared skills and knowledge in starting up such wildly successful companies, but they have also provided the vast majority of employment in the U.S. On average, these immigrant founders create 1200 jobs per company. IS YOUR BOSS AN IMMIGRANT?

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We don’t believe in a world of us versus them; we look at the world as all of us together. “ ” 42 43 In 1991, Dara graduated with a B.A. in biotechnolo- gy engineering from the renowned Brown University. He went on to join Allen & Company as an analyst. Af- ter several years, Dara became President for USA net- works and later Chief Financial Officer for IAC. When IAC purchased Expedia in 2001, Dara quickly rose to the top to become CEO by 2005. By 2015, Expedia gave Dara a $90 million stock option conditioned on him staying with the company until 2020. Under Dara’s tenure, Expedia became the largest on- line US travel agency. They had extended the company’s presence to more than 60 countries worldwide and acquired Travelocity, Orbitz, and HomeAway. Rather than staying on with Expedia, Dara forfeit- ed his unvested stock options to take a CEO position with Uber. He now manages the company’s fast-growing business in over 63 countries worldwide and leads a global team of over 22,000 employees. Dara’s uncle, Mr. Hassan Khosrowshahi is an Irani- an-Canadian billionaire who founded the well-known Canadian chain, Future Shop, later sold to Best Buy. Given Dara’s history, he has been an outspoken critic against the immigration policy of Donald Trump, including the travel ban. He encourages kids to go to school for computer information systems and engineering to learn problem solving, even if they will be entering a different career in the future. 55% of America’s Billion- Dollar Startups have an Immigrant Founder. “ ” Forbes. Anderson, Stuart. October 25, 2018. SPOTLIGHT ON SUCCESS DARA KHOSROWSHAHI n this edition of Spotlight on Success, we would like to focus on one brilliant man who came to the United States as a refugee and is now one of the highest paid CEO’s in the world. Previous CEO of Expedia Group and current CEO of Uber. These are just two of the positions which adorn the CV of Mr. Dara Khosrowshahi. Dara is an Iranian-America born in 1969 to parents Asghar Khosrowshahi, and Lili Khosrowshahi. He was born into a wealthy and affluential business family. In 1978, just before the Iranian Revolution, the family’s company in Iran was seized, and they first fled to southern France to wait out the failing of the revolution. When the revolution did not fail, his family decided to move to the United States to join other family members. Dara was only nine years old when he arrived in New York as an Iranian refugee. The family was separated from Dara’s father when he went back to visit Dara’s ill grandfather, and the Irani- an government would not let him leave for 6 years to go back to the United States. I Some of the U.S.’s biggest companies are founded by immigrants. “ ” Fast Company. Grothaus, Michael. July 26, 2018.