Not by itself. The actual managerial or executive duties, relevant history and applicable transition requirements need assessment. Sequence the assessment: first the entities, then the position, then the person. The employer establishes the qualifying corporate relationship and defines the managerial or executive capacity; only against that definition can the applicant’s proposed duties be tested. An earlier L-1B approval recorded that specialized knowledge was shown at that time for that assignment. It decided nothing about managerial capacity, and it is not evidence the later role exists.
Evaluate the new capacity on its own evidence
Explain how authority and responsibilities change, who performs operational work and what technical duties remain. Previous recognition of specialized knowledge does not establish a different managerial role. Two conditions sit underneath the whole question and should be stated before the duties are argued.
The applicant must have been employed for one continuous year within the preceding three years by a qualifying related entity abroad, and the U.S. role must be managerial or executive in capacity rather than in title. Both are proved by the employer’s records: the organisational chart showing who reports to the position, budget or hiring authority documented somewhere other than the job description, and evidence of the subordinate work being performed by others.
Where the applicant would still carry the technical output personally, say so in the file. A candid description of retained technical duties is assessed; a description that omits them invites the question anyway.