No. The title is not the test. Executive capacity is defined by directing the organisation or a major component, setting goals and policies, wide discretionary latitude and only general supervision from above, and each of those has to be evidenced.
A title describes a chair; the definition describes decisions
Hypothetical example: the president of a family processing company holds the title but every purchase over a modest amount is approved by his mother, who holds the shares, and he spends much of the week on the kill floor solving problems. That is a description of a working owner, not of executive capacity, and the file should be built honestly on whichever definition the facts support. If the American role will genuinely involve directing the subsidiary, setting its policies and answering only to the shareholders, say that and show it: the chart, the delegated authority, the board minutes.
If instead he will manage a function or a department, the managerial definition applies with its own elements. The remaining requirements apply either way — a qualifying corporate relationship with both entities operating, a continuous qualifying year abroad within the last three years, and a seven-year ceiling counting earlier U.S. periods.