Use the actual allocation of duties, decision records and evidence of operational support. Explain what each record establishes.
Account for the recurring work
Select a recurring activity and identify its executor, decision maker and escalation path. Disclose tasks the applicant still performs personally. The explanation should follow the facts rather than remove inconvenient duties from the job description.
Primary corporate records rather than descriptions: share registers or certificates for both entities, the executed purchase agreement with its closing documents, director resolutions, and financial statements or contracts showing each company actively trading. Start with a truthful U.S. duty statement, then connect each responsibility to reporting charts, job descriptions for subordinate staff, approval matrices, budgets, meeting records, and examples of decisions made without routine escalation. Current policies, signed resolutions, payroll records, organization charts, and representative decisions should support the position described at filing; a draft can be included only if clearly labelled and its contingency explained. Corporate records must establish a qualifying parent, branch, subsidiary or affiliate that is doing business, while dated employment evidence must show one continuous foreign year within the relevant three-year window. Useful company evidence may include ownership records, organizational charts, operating records for both entities, payroll proof, and a chronology establishing the employee’s continuous qualifying foreign year within the previous three.