The role requires an individual assessment; headcount alone is not the test.
Explain management of the function
Identify the function, authority and support for operational work. Do not merely rename personal service delivery as management. Hypothetical example: a circular-economy packaging company that wants to transfer the director who oversees supplier strategy.
At a first review, the first review should distinguish authority over a function from personal delivery of supplier work and check the related entities. The records most likely to settle that point are ownership records, reporting lines, job descriptions, foreign payroll, and examples of delegated operational work. Sequence the work deliberately: build the foreign-employment timeline before selecting the filing date, then test the proposed U.S.
role against actual staffing. A common error is using executive-sounding verbs while the calendar shows the transferee will perform the unit’s routine work; that error matters because a conclusion based on incomplete or mismatched facts may not carry to the final arrangement. Write down the decision that remains after the review, the fact that could change it, and the record needed to resolve that fact.
This creates a usable file rather than a collection of documents that cannot be connected to the actual plan.