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Two courts of appeals, Ramirez v. Brown, 852 F.3d 954 (9th Cir. 2017), and Flores v. USCIS, 718 F.3d 548 (6th Cir. 2013), have held that a grant of Temporary Protected Status (TPS) may make an individual eligible for adjustment of status. Both courts held, as a matter of statutory interpretation, that Congress intended TPS recipients to be considered “admitted” for purposes of INA § 245(a). Those who enter without inspection—such as the plaintiffs in both cases— generally are ineligible for adjustment under INA § 245(a).2 Pursuant to Ramirez and Flores, however, a grant of TPS status subsequent to the unlawful entry constitutes an inspection and admission, thus satisfying this § 245(a) requirement. The TPS statute, as interpreted in Ramirez and Flores, does not render a recipient eligible to adjust but rather provides only that the individual meets the one threshold requirement for adjustment.

There are several reasons why limited liability companies - or LLCs - continue to grow in popularity, so here are five benefits to forming an LLC.