The Board of Immigration Appeals has determined that non-citizens subject to the 3- and 10-year bars in section 212(a)(9)(B) of the INA are not required to serve the entire bar outside of the country. “A plain-text reading of section 212(a)(9)(B)(i)(II) of the INA, 8 U.S.C. § 1182(a)(9)(B)(i)(II), indicates that the period of ineligibility runs from the date of departure from the United States and does not require a noncitizen to remain outside the United States for the entire 10-year period of inadmissibility.”
The full text of Matter of Duarte-Gonzalez can be found here: