Explain the actual support and the applicant’s duties rather than apply a blanket assumption.
Describe the real operating arrangement
Identify who performs routine work and what the manager genuinely directs. External services do not automatically prove managerial capacity, but they should not be hidden simply because they are not payroll employees.
Map every operational task to the person or provider who actually performs it, then separate directing employees from simply overseeing a contractor's results. Executed service agreements, invoices, reporting routines, and evidence of real authority may show that a manager is relieved of routine production, but a vendor does not automatically count as a subordinate. L-1A also requires one continuous year of qualifying foreign employment during the preceding three years, a parent, branch, subsidiary, or affiliate relationship, ongoing foreign business and, unless the U.S. operation is a new office, ongoing U.S. business, with U.S. duties that are primarily managerial or executive. For a new-office L-1A, the foreign year must have been in a managerial or executive capacity. A new-office petition only gets one year to prove itself, so the record needs sufficient physical premises, the foreign entity’s financial ability to remunerate the beneficiary and commence doing business in the United States, and a credible plan for the operation to grow into a role that is genuinely managerial or executive by the time that year runs out.
Hypothetical example: A cabinet-hardware distributor in Rivière-Éternité proposes transferring its operations director while outsourcing US bookkeeping and fulfillment. The company identifies the employees she directs, the decisions she controls, and the outcomes covered by each vendor agreement, without counting the bookkeeper and fulfillment firm as payroll staff. Corporate ownership records connect the two businesses, payroll, travel history, and foreign-duty records establish her uninterrupted year in a managerial capacity, and a duty calendar tests whether vendor oversight leaves her chiefly directing the function rather than packing orders herself.