No. Assess the actual proposed U.S. managerial or executive capacity as well as the relevant foreign employment and other requirements.
Describe the work being transferred into
Identify the new responsibilities, discretion and support. A previous managerial position can be relevant history without proving that a different implementation role meets the same standard. Keep the two duty accounts distinct.
USCIS has repeatedly stated that a small company can support an L-1A petition and equally that a small company's owner or general manager is not automatically a manager in the regulatory sense. A qualifying function-manager analysis may be relevant, but absence of direct reports is not itself an eligibility rule. Identify the relevant entities, ownership and control after the transaction. Reconstruct physical presence day by day, but keep excluded U.S. days distinct from a break in continuous foreign employment. For a people manager, show that subordinates are professionals or supervisors and that the transferee hires, evaluates and directs them. The regulation requires employment by the qualifying entity, and a contractor billing for warranty work is not its employee. Ownership or control may change at a later closing, so signature alone may not establish the relationship the filing relies on.