Not necessarily. Assess how long the actual U.S. organization has been doing business.
Date the relevant operation
Registration, overseas history and current U.S. activity are different facts. The applicable new-office analysis concerns the real organization and its business, not merely the age of the brand.
Immediately after closing, the corporate secretary should update the register and issue certificates for the U.S. entity, and the group's registers should be brought current on the Canadian side as well. What matters at the extension stage is the operation that actually developed — a later forecast cannot substitute for that record, and a business deadline does not extend an authorized period of stay. Qualifying employment abroad is generally measured as one continuous year within the relevant preceding three-year period, and how that is counted in an individual history is a question for counsel. A new-office approval is generally granted for one year initially, and the extension is assessed on what the operation actually became rather than on what was projected — which makes the first year an evidence period rather than a settling-in period.