Explain the actual phases and have the applicable role and new-office requirements assessed. Do not describe future responsibilities as already established.
Connect the timing to the actual operation
Identify who performs the initial work and what support would change later. A promised promotion date does not establish immigration eligibility. Keep the proposed start subject to the appropriate assessment and process.
New-office extension requirements also need their own later evidence and decision. Longer coverage cannot turn operational work into management by repetition. A new office starts under a one-year approval framework, while accumulated L-1A time is generally limited to seven years.
Reassess the applicant’s actual interim duties and support rather than assume the original split remains unchanged. Identify whether employment terms, duties or ownership arrangements also changed. Explain how the delay affects duties, staffing and the business account. Identify which duties would begin, where they would occur and the intended date. The general rule allows the qualifying period abroad to be managerial, executive, or specialized-knowledge work, but the new-office standard for this particular classification is narrower: the foreign qualifying period itself has to have been managerial or executive, not merely specialized-knowledge work, regardless of which phase the person's own United States duties are planned to begin. Confirm which version of the standard actually applies before assuming a phased plan satisfies the broader general rule.