FEB172026_01B4203Decided 2026-02-17I-140

The AAO remanded an EB-1C petition for a carpentry business because SCOPS denied it without adequately explaining its…

Remanded Useful for: appeal strategy
EB-1CField: carpentry business
The outcome

Good news — this case cleared the first bar

The AAO withdrew SCOPS' denial and remanded the matter because SCOPS failed to adequately explain its reasons for denial and did not discuss the probative value of the submitted evidence, denying the Petitioner a fair opportunity to contest the decision.

In plain English

A carpentry business sought to permanently employ its general manager under the EB-1C multinational manager or executive classification. SCOPS denied the petition on grounds that no qualifying relationship with the foreign employer was established and the proposed U.S. employment was not managerial or executive. The AAO found SCOPS' decision procedurally deficient because it failed to discuss the probative value of submitted evidence or provide specific reasons for denial. The AAO also found substantive errors, including SCOPS improperly relying solely on headcount to deny managerial capacity and raising the managerial capacity issue in the denial without giving the Petitioner an RFE opportunity to respond. The matter was remanded for a new decision addressing qualifying relationship, managerial/executive capacity, multinational status, and the Beneficiary's prior qualifying employment abroad.

What worked & what failed

What worked: The AAO agreed that SCOPS' decision was procedurally deficient for failing to explain its reasoning and discuss submitted evidence, warranting a remand. The AAO also noted that SCOPS improperly used employee headcount as the sole basis for denying managerial capacity, which is not permitted under the law.

What failed: The record contained significant evidentiary problems on remand, including: the foreign entity appeared to have wound down after the owner's death in 2024 with no evidence of licensing continuity; post-RFE documents were created after the RFE and raised authenticity concerns; and the Petitioner's own tax filings showed no employees or wages in the filing quarter, contradicting claimed staffing levels.

Takeaway: For EB-1C petitions, petitioners must proactively document the qualifying relationship with clear ownership/control evidence and demonstrate continuous business operations of the foreign entity through the date of adjudication. USCIS must address all submitted evidence and give petitioners RFE opportunities before raising new denial grounds.

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

  • The AAO agreed that SCOPS' decision was procedurally deficient for failing to explain its reasoning and discuss submitted evidence, warranting a remand
  • The AAO also noted that SCOPS improperly used employee headcount as the sole basis for denying managerial capacity, which is not permitted under the law.

Evidence that wasn't enough alone

  • The record contained significant evidentiary problems on remand, including: the foreign entity appeared to have wound down after the owner's death in 2024 with no evidence of licensing continuity
  • post-RFE documents were created after the RFE and raised authenticity concerns
  • and the Petitioner's own tax filings showed no employees or wages in the filing quarter, contradicting claimed staffing levels.
Find more EB-1C cases with similar evidence patterns →
Evidence that persuaded the AAO

Articles of incorporation and stock certificates showing ownership history of the U.S. petitioner

Federal tax returns (IRS Form 1120-S) for 2023 and 2024 identifying the Beneficiary as sole shareholder

Government-issued registration and license information for the foreign entity confirming its 1983 registration

Memorandum of association and commercial license for the foreign entity dated July/August 2025

Purchase orders, contracts, and invoices dated 2024 and 2025

Where the evidence fell short

Post-RFE documents (memorandum of association, trade license, lease agreement) all post-dated the RFE issuance, raising questions about continuous business operations

Invoices dated 2024 listing a company address that was not leased until July 2025, undermining their credibility

No evidence the foreign entity remained licensed after 2019 or reincorporated prior to 2025

IRS Form 941 for Q1 2025 (the filing quarter) showed no employees and no wages paid, undermining claimed staffing levels

Petitioner's own letter stating the foreign entity 'was wound up' after the owner's death in March 2024

Officer errors the AAO found

SCOPS failed to specifically address the Petitioner's claims or discuss the probative value of submitted evidence

SCOPS concluded no qualifying relationship existed without discussing the evidence of ownership and control in the record

SCOPS improperly relied solely on the number of employees (8) to deny the managerial/executive capacity finding, without considering all relevant factors such as job duties, organizational structure, and subordinate employees

SCOPS raised the managerial/executive capacity issue in the denial without first raising it in the RFE, denying the Petitioner an opportunity to respond

SCOPS' decision was insufficient to provide the Petitioner a fair opportunity to contest the denial on appeal

How the case moved

Completed

I-140 filed

General manager of a carpentry business

Completed

SCOPS — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2026-02-17

AAO decision — Remanded

The AAO withdrew SCOPS' denial and remanded the matter because SCOPS failed to adequately explain its reasons for denial and did not discuss the probative value of the submitted evidence, denying the Petitioner a fair opportunity to contest the decision.

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. § 103.38 C.F.R. § 103.3(a)(1)(i)8 C.F.R. § 204.5(j)(2)8 C.F.R. § 204.5(j)(3)(A)-(D)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)
ChawathePetitioner bears the burden of proof to demonstrate eligibility by a preponderance of the evidence
Christo'sAAO conducts de novo review on appeal
M-P-A decision must fully explain the reasons for denial to allow the respondent a meaningful opportunity to challenge on appeal
Church ScientologyOwnership and control are the factors that determine whether a qualifying relationship exists between U.S. and foreign entities
SiemensOwnership and control are the factors that determine whether a qualifying relationship exists between U.S. and foreign entities
HughesOwnership and control are the factors that determine whether a qualifying relationship exists between U.S. and foreign entities
F-M- Co.Both the U.S. employer and at least one qualifying organization abroad must continue to do business until the Beneficiary is issued an immigrant visa or adjusts to permanent resident status
S-P-Governs whether the Beneficiary was employed in a managerial or executive capacity abroad for at least one year during the requisite three-year period