EB-1C I-140 938 cases analyzed

How to Respond to an EB-1C Multinational Manager RFE

Managerial and executive capacity is the single biggest fight in EB-1C appeals — here's what the AAO actually wants to see.

Cases analyzed
938
AAO appeal decisions
Sustained
14%
appeal fully successful
Remanded
18%
error found, sent back
Dismissed
68%
appeal not successful
What triggers this RFE
  • The organizational chart doesn't show enough subordinate staff or clear reporting lines to support genuine managerial capacity.
  • Job duties read as “first-line supervisor” or hands-on technical work rather than managing an organization, department, or function.
  • The one-year-abroad requirement isn't clearly documented with dates, payroll, and the qualifying relationship between the foreign and U.S. entities.
  • For small or new U.S. offices, staffing and growth projections aren't concrete enough to support the claimed managerial role.
How to structure your response
  • Submit a detailed org chart with named subordinates, their titles, FTE status, and brief duty descriptions — not just a list of headcounts.
  • Use the statutory language directly: show the petitioner manages the organization, a department, or a function, and exercises discretion over staffing and operations.
  • Document the one-year-abroad period with foreign payroll records, offer letters, and a clear statement of the qualifying corporate relationship.
  • For new offices, include a credible staffing timeline and evidence the U.S. entity can support a genuine managerial position within a reasonable period.
Evidence that actually persuaded the AAO
Evidence that wasn't enough alone

Remanded · 2016 2013 corporate tax return, unaudited balance sheets, unaudited income statements, state quarterly wage reports, and bank statements were insufficient to establish ability to pay — they do not meet the regulatory requirement of annual reports, federal tax returns, or audited financial statements for the relevant filing period

Dismissed · 2020 Petitioner's claim that late filing of the motion to reconsider was beyond its control due to not receiving the denial notice — the regulation at 8 C.F.R. § 103.5(a)(1)(i) does not provide discretionary relief for untimely motions to reconsider (only motions to reopen), and the denial was mailed to the address of record.

Remanded · 2015 Translation of the parent company's Operating Report and Account Closing 2013, which contained an untranslated Finnish heading in the right-hand column and a discrepancy where '100.00' appeared in translation but only a dash appeared in the original, rendering the translation incomplete and potentially inaccurate

Remanded · 2025 Two organizational charts depicting the Beneficiary as production manager and project manager on the 'Pavillion Project Team' — the AAO found these pertained to the continuous improvement manager role, not the regional manufacturing strategy manager role, and were therefore not relevant to the qualifying period.

Remanded · 2017 The lengthy description of the Beneficiary's proposed duties was found insufficiently detailed to establish primarily executive functions — activities like penetrating new markets, securing clients, and refining sales strategy were viewed as operational sales/marketing tasks rather than directing management.

Officer errors that got real cases remanded
Officer error the AAO identified2024

The Director applied the incorrect definition of 'affiliates' under 8 C.F.R. § 204.5(j)(2)(C), failing to account for the special accounting-firm affiliate definition covering firms providing accounting and consulting services under the same internationally recognized name under a worldwide coordinating organization owned and controlled by member firms.

Officer error the AAO identified2017

The AAO partially reversed the Director by finding, on appeal, sufficient evidence that the Beneficiary worked in an executive capacity abroad, that the Petitioner had been doing business for one year prior to filing, and that the Petitioner had the ability to pay the proffered wage — issues the Director had decided against the Petitioner.

Officer error the AAO identified2020

The Director's finding of willful misrepresentation of material facts was not supported — the identified document deficiencies did not rise to the level of willful and material misrepresentation, and the Director's own finding that the documents were not relevant meant they could not be material for misrepresentation purposes.

Officer error the AAO identified2020

The Director exceeded the scope of the AAO's prior remand order by raising new issues (U.S. executive capacity and foreign executive capacity) beyond the single limited issue that was remanded (whether the Beneficiary was employed abroad by the foreign employer for at least one year in the three years preceding U.S. entry).

Officer error the AAO identified2022

The Director incorrectly applied 8 C.F.R. § 204.5(j)(3)(i)(A) (qualifying period measured from petition filing) instead of 8 C.F.R. § 204.5(j)(3)(i)(B) (qualifying period measured from U.S. entry as a nonimmigrant) because the beneficiary was already working for the petitioner in the United States at time of filing.

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See all 938 EB-1C cases →