International trade is not required by the L qualifying-organization definition. The group still needs the required relationship and continuing qualifying business in the United States and abroad.
Explain operations as they actually exist
A company can provide services to its own customers without inventing shipments to its affiliate. The employee’s foreign employment and proposed managerial or executive job must still be established.
Identify the entity operating the location and when it began doing business. Explain what the applicant can decide, what must be approved elsewhere and who performs routine work. Weigh the position by what the applicant actually decides and delegates, not by how many storefronts sit on an org chart. The relationship is established by the closing documents and the stock ledger, not by the fact of the deal.
What makes or breaks the claim is documentation: the ownership must be shown, not asserted, and both companies must be actively conducting business. Document each entity's own customers, contracts and invoices rather than looking for shipments or transactions between the two organizations, since the qualifying relationship concerns ownership, control and continuing operations rather than trade flow. Identify the staff who perform the work generating that revenue for each entity, and confirm both sides show ongoing activity rather than one operating and the other sitting idle. Ask for records showing each organization served its own customers during the relevant period, because that evidence supports continuing operations regardless of whether goods or services ever moved between the affiliated companies.