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BROCK · L-1A FIELD GUIDE

How do I show that the foreign business continues operating?

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THE DIRECT ANSWER

Use dated records of actual goods or services, supported by financial, staffing and customer or internal transaction evidence appropriate to the business. Company registration documents establish identity, but do not themselves demonstrate ongoing activity.

Build an operating timeline

Organize evidence by period and explain who performs the work after the manager transfers. Reconcile contracts, invoices and payments where those records exist, without presenting unsigned opportunities as completed business. Internal group services can require explanation of what is delivered and why it matters.

An extension review should be able to follow operations across the year rather than relying on a single recent transaction. Build an operating timeline rather than a folder, so that a reader can see activity distributed across the period rather than clustered around the filing date. Take each quarter and identify what the foreign business did: contracts signed or renewed, invoices raised, payments received, payroll run, filings made, suppliers paid.

Attach a representative document to each entry rather than everything. Include the records that are hard to create retrospectively, such as tax filings and bank statements, since those carry weight precisely because their timing is fixed. Where activity is genuinely seasonal, present it as seasonal and explain the pattern rather than leaving gaps to be interpreted.

And keep the timeline going after filing, because the same evidence in a later period is what an extension will turn on.