The actual duties and organizational support need assessment. Headcount alone does not decide every case, but the applicant cannot principally perform operating work while relying only on a manager title.
Explain who does the work after the change
Identify which responsibilities are delegated and which remain with the applicant. For a function manager, show senior authority over an essential function. First-line supervision of nonprofessionals alone is not enough.
Ownership can help explain the corporate relationship, but the qualifying foreign employment, a parent, branch, subsidiary or affiliate relationship, both the foreign and U.S. entities remaining active, and a primarily managerial or executive U.S. role still need independent evidence. Only if the preceding eight months of senior-analyst work involved specialized knowledge of the firm’s methods, so that a continuous qualifying year exists; otherwise the petition should wait until twelve months as a manager have accrued. Supervising professional employees supports the showing, while a first-line supervisor of routine work does not qualify merely by holding a supervisory title, and the classification looks at whether the applicant manages an organisation, department, subdivision, function, or component.