Gather the history relevant to the company’s actual office classification and the period counsel must assess. New-office and established-office petitions use different frameworks, so the answer is not a universal number of invoices or months.
Make the timeline visible
Identify when regular U.S. business activity began and preserve records across that period. Do the same for continuing qualifying foreign operations.
Do not use incorporation alone as the operating start date without checking the facts. Preparation time should include explaining unusual cycles or gaps before the government process begins; a rushed recent transaction does not substitute for an accurate operating history. Establish when regular activity actually began, since that date is frequently not the one everybody assumes.
Incorporation is a legal event and may precede trading by a considerable period, so check the facts rather than using the registration date as an operating start. Preserve records across the relevant period for the U.S. entity and for the continuing qualifying foreign operations, which are assessed separately.
New-office and established-office petitions use different frameworks, so the history required is not a fixed number of months or invoices. Allow preparation time to explain unusual cycles or gaps before the process begins, because a transaction arranged quickly at the end does not substitute for an accurate history.