No. First-line supervision of nonprofessional employees does not qualify merely by virtue of supervisory duties. Examine the complete managerial or executive definition and the role’s primary duties. A possible function-manager case must establish its own elements rather than relabelling frontline supervision.
Look beyond the number of direct reports
Describe the workers’ actual responsibilities and qualifications, the applicant’s authority and who carries out the managed function’s operating work. An organization chart can clarify these facts, but adding more boxes or changing job titles without changing the real roles does not cure an unsupported claim. First review produces an authority map: which decisions the transferee makes, who performs the underlying service, and where the transferee sits in the organization.
The most probative records are delegation documents, job descriptions for the staff layer, and examples of actual approvals. Sequence the case by testing the foreign role, the US role, and the corporate relationship separately. A claim often fails when a supervisory title is asked to carry facts showing routine frontline delivery.
Hypothetical example: A Canadian museum-exhibit company wants to transfer its regional director to supervise installation crews. Her signed budgets, hiring authority, and reports from project leads matter more than the director title if she also spends most days assembling display cases.