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Change of status, amendment and extension of existing H1B visas are exempt. But yeah transfers are not explicitly called out one way or another. Feels like a gray area currently.
D1 - check with your new employer’s counsel. Mine just told me to not travel until there’s more guidance from DOS…my transfer was approved without fee before the new guidance from USCIS came down but after September 21, but immigration counsel said it’s unclear if consulate will ask for it when I apply for a stamp. I wouldn’t move over if you have international travel plans
will this be beneficial for the US employer? this means existing H1b visa holders are 'stuck' with them, discouraging looking for better work and prolong the servitude