Yes, if the position primarily manages an essential function of the organization at a senior level, rather than personally performing that function's operational tasks. The absence of direct reports is not disqualifying by itself, but it does raise the evidentiary bar to show genuine functional authority rather than technical seniority.
Focus evidence on control over outcomes
Describe what Priya approves, prioritizes and is accountable for at the functional level, and who executes the resulting work even if they report elsewhere on paper. A reviewer will look for a credible separation between managing the function and doing the function's work; blending the two undermines the claim regardless of title.
A first review should produce three separate findings: the companies have the required relationship, the employee completed qualifying work abroad in the relevant period, and the proposed position is managerial or executive in substance. Start with ownership and governance documents, then build an employment timeline from payroll and personnel records, and finally map delegated authority in both roles. Hypothetical example: A renewable-energy procurement director has a senior title but personally negotiates every purchase order because no staff report to her. The company should document whether she manages a function at a senior level with real discretion, or whether the title conceals a primarily individual-contributor job. The petition cannot substitute planned growth for current facts without explaining the structure and authority. It must also account for the maximum seven-year L-1A period and any prior L classifications that may count toward it. A precise conclusion tells the organization what still needs proof before filing.