Not by itself. Identify the actual qualifying period under the relevant timeline.
Use dates and duties together
A total number of career years is not a substitute for the required continuous foreign employment. Explain the individual chronology and relevant work records accurately.
Physical premises secured for the operation, a qualifying relationship between the entities, qualifying employment abroad, and evidence that the operation will support a managerial or executive position within one year. A qualifying relationship exists where one entity owns and controls the other, or where the same parent or the same group of individuals owns and controls both, each individual holding approximately the same share and proportion in each. If an essential-function management theory applies, identify the function, senior-level authority and discretion, and demonstrate that the applicant primarily manages rather than performs it. The qualifying relationship is about structure: ownership and control between the U.S. employer and the foreign entity, which a share transfer during a restructuring can change without anyone thinking about immigration. For an established-office case, confirm that the qualifying organization is doing business in the United States and at least one other country; for an initial new-office case, confirm foreign operations and the separate new-office requirements.