Prepare ownership records, evidence of business activity, foreign employment and compensation records, and selected examples of the owner’s specialist work. A share register alone does not prove the employment or knowledge requirements.
Explain overlapping roles
Use a truthful duty breakdown showing specialist, managerial and administrative responsibilities. Support the knowledge claim with product, process, training or project evidence that others can corroborate where possible. Explain how the foreign operation will remain active after the transfer and how the proposed U.S.
duties fit the actual operating plan, especially for a new office. Produce a duty breakdown a reviewer can check against other records in the file. Express it as proportions of working time across specialist, managerial and administrative activity, and derive it from calendars, project logs and delegation records rather than from an estimate written for the petition.
Then attach the supporting material for the specialist portion: product or process documentation, training delivered, and specific problems the person resolved. A share register belongs in a different bundle and proves neither employment nor knowledge. Where the owner performs administrative work any employee could do, include it honestly, because a breakdown showing only specialist activity invites the question of who does everything else in a small company.
What most often settles a doubt here is the payroll record, since it shows whether the person was employed by the foreign entity at all.