The actual managerial requirements and support need review; one administrative reporting line does not decide the whole case.
Describe who directs the function
Identify the applicant’s authority, the work managed and who performs delivery. Do not use a function-manager label to conceal that the applicant personally carries out the essential operational tasks.
Ownership can help explain the corporate relationship, but the qualifying foreign employment, the actual business activity of both entities, and the proposed managerial or executive role in the U.S. still each need to be established independently. Supervising three supervisors who each direct their own staff supports a personnel-management case, and the evidence is the reporting structure with names, positions and the duties of the people supervised. A custom-harvest operations manager who recruits crews, sets routes, negotiates with growers and controls the equipment budget performs those functions. A production function managed at a senior level looks like setting standards, choosing suppliers and processes, allocating capacity and being accountable for results. Reconstruct the temporary coverage job by allocating time among personnel decisions, budgets, policy, supervision of professional staff, customer delivery, and hands-on production. The decision-maker should be able to see who manages professional, supervisory or managerial employees, or which function is directed at a senior level, rather than infer executive work from a senior title.