No. Assess the actual relevant qualifying period and individual timeline.
Identify which employment counts
A long career can include periods that do not establish the proposed transfer. Use genuine employers, dates and duties rather than one accumulated number.
The regulation defines affiliate to include two legal entities owned and controlled by the same group of individuals, each individual owning and controlling approximately the same share or proportion of each entity. With ownership records for both companies showing the same individual or group owns and controls each in roughly the same proportions: share registers, articles, shareholder agreements and, where relevant, tax filings that list owners. L-1A preparation should explain each person’s actual authority and primary responsibilities instead of assuming that a shared function proves both roles or automatically prevents either role from qualifying. Separately prove a parent, branch, subsidiary, or affiliate relationship, continuing foreign business and either active U.S. business or, for a new office, the ability to commence it, and one continuous qualifying year abroad within the previous three. The first review should identify the corporate records proving the qualifying relationship, payroll evidence showing an uninterrupted year abroad during the three-year lookback, and a duty record showing managerial or executive authority.