Only if the preceding eight months of senior-analyst work involved specialized knowledge of the firm’s methods, so that a continuous qualifying year exists; otherwise the petition should wait until twelve months as a manager have accrued.
A recent promotion does not restart the year, but it does change what must be proven
The regulation asks for one continuous year of qualifying employment abroad in the three years before filing, and the petition must establish that the year was in a managerial, executive or specialized-knowledge capacity. A promotion four months ago does not defeat the case; it simply means the year is made up of two different capacities. Four months as practice manager are managerial.
The eight months before must be shown to involve specialized knowledge, meaning advanced knowledge of the firm’s proprietary evaluation frameworks and their application to client work, which is a higher bar than being a competent analyst. If the employer cannot document that, the reliable course is to file after a full year in the managerial role. In either event the U.S.
position must be primarily managerial, the affiliate relationship must be proven with ownership records, and both firms must remain in business. Hypothetical example: a theatre-company general manager spent ten months running budgets and two months producing performances herself before the proposed transfer. A first review should calendar the twelve continuous months and separate the managerial evidence from the production work.
The records that matter are reporting lines, budget authority, and dated job descriptions. If the nonmanagerial period breaks the qualifying year, waiting may be safer than calling every duty executive.