No. Explain actual primary responsibilities and operational support.
Describe what the organization does
A headcount does not show who performs the recurring work or what the applicant manages. Avoid a universal numerical shortcut.
An organization chart placing site coordinators and consultants under your direction, engagement letters with audit firms you select, policies bearing your approval but drafted by others, budget approvals, and correspondence in which staff take instruction from you. A strong chart answers three questions at a glance: who the transferee will supervise, whether those people are supervisory or professional employees, and who performs the day-to-day operational work if the transferee is not doing it. Current policies, signed resolutions, payroll records, organization charts, and representative decisions should support the position described at filing; a draft can be included only if clearly labelled and its contingency explained. Formation documents, shareholder records and tax or financial material should establish the entities’ relationship; payroll, contracts and leave records should establish the worker’s chronology; organization charts, job descriptions and budgets should establish the US role. Corporate records must also establish the parent, branch, subsidiary, or affiliate link and show that the foreign organization is doing business; a non-new-office case must also show U.S. operations.