No. Assess the actual responsibilities, discretion and primary duties with the other L requirements. Compensation alone is not the role test.
Describe what the person does
Identify the decisions made, support available and routine work retained. A package described as executive compensation should not be used to imply authority the employer has not actually assigned.
Managerial capacity can rest on supervising other employees, in which case the subordinates and their own duties are examined, or on managing an essential function of the organization at a senior level, in which case the function itself must be identified and its importance demonstrated. Ownership can help explain the relationship between the organizations, but the qualifying employment, actual business activity and proposed managerial or executive role still need to be shown separately. Obtain the employer’s account and supporting records, and assess the required continuous qualifying year abroad in the relevant three-year period. Map the transferred executive’s routine tasks to named employees or genuine contractors, supported by payroll, schedules, agreements, and operating records. Headcount is relevant context, not a substitute for proving primarily managerial or executive duties; a function manager must primarily manage the function rather than primarily produce its ordinary output.