An accurate organizational chart, a written description of the function's scope and decision rights, evidence of the specialists who execute the function even without a direct reporting line, and documentation of the qualifying corporate relationship between the two entities.
Prioritize substance over polished titles
A detailed narrative describing recent decisions Priya made about the function — priorities set, budget approved, standards enforced — is generally more persuasive than a job description restating duties in managerial-sounding language. Keep supporting evidence, such as email approvals or budget records, consistent with the narrative rather than contradicting it.
Organize documents by proposition, not by source. Corporate records should establish ownership and control; payroll, tax, HR, and duty records should establish the overseas employment; organization charts, budgets, hiring authority, and job descriptions should establish the U.S. leadership role. Date every chart and identify the preparer, because an undated diagram cannot show when a structure existed. Hypothetical example: A freight-terminal director is transferred after a corporate reorganization, and the group submits a polished chart with no supporting share records. The chart is helpful context, but the share register and transaction documents settle the relationship. Preserve both the old and proposed reporting lines so a reviewer can see what changed. If the U.S. entity is newly established, include premises, capitalization, launch plan, and staffing evidence tailored to the new-office question rather than recycling an operating-company package.
Keep an index that names the custodian for each corporate record and the period it covers. If ownership is documented through several holding companies, trace every link and preserve the originals. This avoids an attractive summary chart becoming the only evidence of control.