DEC202016_02B4203Decided 2016-12-20I-140

The AAO dismissed an EB-1C multinational manager petition for a plumbing contractor's vice president, finding failures…

Dismissed Useful for: avoid these mistakes
EB-1CField: plumbing and heating contractorOrigin: Albania
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to establish a qualifying relationship with the foreign employer, failed to show the beneficiary would work in a managerial or executive capacity, and failed to demonstrate ability to pay the proffered wage. Each ground was treated as an independent basis for denial.

In plain English

A plumbing and heating company sought to permanently transfer a foreign national as its vice president and administrator under the EB-1C multinational manager classification. The AAO upheld denial on three independent grounds. First, the petitioner failed to establish a qualifying affiliate relationship because share certificates were contradicted by tax returns listing only one shareholder, and key corporate documents were never provided. Second, the proposed job description described data entry and first-line supervision of non-professional staff — not managerial or executive duties — and the organizational chart was internally inconsistent with the written description. Third, ability to pay was fatally undermined by the petitioner's contradictory claims about whether the beneficiary had ever worked in the U.S., which cast doubt on the authenticity of submitted payroll documents. The decision illustrates that credibility problems on any one issue can compound findings on others.

What worked & what failed

What failed: 1. Ownership documentation was internally contradictory: share certificates showed two shareholders in 2013, but the company's own tax return for that year reported only one shareholder, and the petitioner never produced corporate bylaws, stock ledgers, or meeting minutes to resolve the conflict. 2. The job description listed clerical and first-line supervisory tasks (data entry, supervising administrative assistants, bookkeeping) that do not meet the statutory definition of managerial or executive work, and the organizational chart was inconsistent with the description. 3. The petitioner made irreconcilable statements about whether the beneficiary worked in the U.S.: initial filings included pay stubs, while the appeal claimed he never worked there, destroying the credibility of both sets of claims and leaving no reliable evidence of ability to pay.

Takeaway: For EB-1C petitions, petitioners must provide complete corporate documentation (stock ledgers, bylaws, meeting minutes) to prove ownership and control, ensure all filings are internally consistent, and never make contradictory factual representations across stages of the proceeding — inconsistencies on credibility grounds can defeat even otherwise supportable claims.

For RFE responses & petition building

Cases like this are frequently used by attorneys when responding to RFEs or building initial petitions. The evidence patterns that worked (or failed) here directly reflect what USCIS officers look for when evaluating EB-1C criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • Ownership documentation was internally contradictory: share certificates showed two shareholders in 2013, but the company's own tax return for that year reported only one shareholder, and the petitioner never produced corporate bylaws, stock ledgers, or meeting minutes to resolve the conflict
  • The job description listed clerical and first-line supervisory tasks (data entry, supervising administrative assistants, bookkeeping) that do not meet the statutory definition of managerial or executive work, and the organizational chart was inconsistent with the description
  • The petitioner made irreconcilable statements about whether the beneficiary worked in the U.S.: initial filings included pay stubs, while the appeal claimed he never worked there, destroying the credibility of both sets of claims and leaving no reliable evidence of ability to pay.
Find more EB-1C cases with similar evidence patterns →
Evidence that persuaded the AAO

2013 IRS Form 1120S showing net current assets of approximately $417,748, acknowledged as sufficient to cover proffered salary on its face

Albanian commercial register records showing shared ownership of the foreign company

Where the evidence fell short

Share certificates numbered 2 and 3 for the U.S. company, which were unsupported by stock ledgers, bylaws, or meeting minutes and contradicted the 2013 tax return listing only one shareholder

Job description claiming vice president/administrator role, found to describe data entry and first-line supervision of non-professional staff rather than managerial or executive duties

Payroll documents and pay receipts for January-February 2015, undermined by contradictory statement on appeal that the beneficiary never worked in the U.S. and by bank statements not reflecting corresponding withdrawals

Organizational chart listing superintendents as subordinates, where the job description never mentioned them or the beneficiary's authority over them

Unsupported appellate claim that company relies on subcontractors, raised for the first time on appeal without documentary support

2014 and 2015 income tax returns, referenced in the RFE response cover letter but not actually present in the record

Officer errors the AAO found

Director quoted the beneficiary's foreign job description instead of the U.S. job description when analyzing the U.S. managerial/executive capacity, though this did not affect the ultimate outcome

How the case moved

Completed

I-140 filed

Vice president and administrator of a plumbing and heating contracting company

Completed

Texas Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

Petitioner appealed to the Administrative Appeals Office for de novo review.

2016-12-20

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to establish a qualifying relationship with the foreign employer, failed to show the beneficiary would work in a managerial or executive capacity, and failed to demonstrate ability to pay the proffered wage. Each ground was treated as an independent basis for denial.

If you're appealing a similar decision, I-290B must be filed within 30 days of personal service of the denial, or 33 days if mailed.

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Authorities the office relied on
8 C.F.R. § 204.5(j)(3)8 C.F.R. § 204.5(j)(3)(i)(A)8 C.F.R. § 204.5(j)(3)(i)(B)8 C.F.R. § 204.5(j)(3)(i)(C)8 C.F.R. § 204.5(j)(3)(i)(D)8 C.F.R. § 204.5(j)(2)8 C.F.R. § 204.5(j)(4)(i)8 C.F.R. § 204.5(j)(5)8 C.F.R. § 204.5(g)(2)8 C.F.R. § 204.5(k)(2)8 C.F.R. § 103.2(b)(14)
Siemens Med. Sys.Stock certificates alone are insufficient to establish ownership and control; corporate ledgers, bylaws, and shareholder meeting minutes must also be examined
Matter of HoWhen conflicting evidence exists, independent and objective evidence is needed to resolve the discrepancy; credibility concerns may undermine a petitioner's claims
Church Scientology Int'lOwnership and control are the determinative factors for qualifying relationships; ownership is the legal right of possession and control is the legal right to direct operations
Matter of HughesOwnership and control determine qualifying relationships between U.S. and foreign entities for multinational manager/executive classification
Matter of SofficiUnsupported statements carry very limited weight and are normally insufficient to meet the burden of proof when supporting documentary evidence would be available
Matter of ChawathePetitioner must support assertions with relevant, probative, and credible evidence
Matter of ObaigbenaUnsupported assertions of counsel do not constitute evidence
Matter of LaureanoUnsupported assertions of counsel do not constitute evidence
Matter of Ramirez-SanchezUnsupported assertions of counsel do not constitute evidence
Matter of OtiendeIn visa petition proceedings, the burden of proving eligibility remains with the petitioner
Systronics Corp.USCIS may consider company size and absence of operational staff as factors bearing on whether a position is managerial; claims of fact may be rejected when there is reason to doubt their truth
Family, Inc.USCIS may properly consider an organization's small size as one factor in assessing whether its operations are substantial enough to support a manager
Republic of TranskeiSmall organizational size is a relevant factor in evaluating managerial capacity claims
Fedin Bros.Small organizational size is a relevant factor in evaluating managerial capacity claims
Q Data ConsultingSmall organizational size is a relevant factor in evaluating managerial capacity claims
Matter of Treasure CraftUnsupported statements are insufficient to carry the burden of proof when documentary evidence would be available