No. The requirement concerns qualifying full-time jobs under the applicable rules, including eligible workers and employment relationships. Paying ten people, counting the investor’s family or aggregating unrelated contractor work is not a sufficient analysis.
Review the actual positions
Prepare a list of roles, employing entities, hours and available worker evidence for counsel. Distinguish a position from changes in the person filling it so turnover is not double-counted. For regional-centre models, use the applicable economic methodology and statutory limits instead of a payroll-only test.
General economic benefit does not replace the required job evidence. Work from the position outwards rather than from the payroll inwards. List the positions the enterprise requires, then the hours attaching to each, then the employment relationship, then the person occupying it.
Counting people first produces exactly the error described, because a headcount conflates positions with turnover and contractors with employees. Hypothetical example: a repacking facility pays fourteen individuals across a year to fill nine full-time positions, two of which stood vacant for a quarter and one of which is held by a relative of the investor. The relevant analysis concerns qualifying full-time positions and the eligible workers filling them, not the fourteen payments.
Distinguish a position from changes in the person occupying it so turnover is not double-counted. Where a regional-centre model applies, the applicable economic methodology and statutory limits govern instead of a payroll-only test, and general economic benefit does not substitute for the required evidence.