Potentially, but the complete evidence must support a primarily managerial or executive role. The number of employees is not the sole test, and outsourcing some tasks does not automatically establish qualifying management.
Test what the support accomplishes
Identify the tasks actually performed by providers and the beneficiary’s remaining work. A function manager must primarily manage an essential function, while a personnel-management claim has its own requirements. Do not treat contractors as qualifying subordinate employees without legal analysis.
Counsel should assess the real structure, business activity and office stage together with the company relationship and foreign employment. Take each function the company performs and write the owner beside it: sales, engineering, assembly, installation, service, invoicing, compliance. Mark whether that owner is an employee, an affiliate, a contracted provider, or the beneficiary personally.
The pattern that emerges is the real answer, and it is more informative than any narrative. Hypothetical example: a warehouse robotics integrator outsources mechanical fabrication and retains system design in-house. If the beneficiary personally performs the design, design is not a managed function.
If the beneficiary sets the design standard, allocates the work and reviews the output, the claim is stronger and the evidence should show those decisions. Keep the corporate side visible in the same review. The qualifying year abroad must fall within the three years before the petition, and the U.S.
entity must stand in a qualifying relationship to the foreign employer.