Review the spouse’s actual qualifying status and documentation.
Coordinate the individual records
The principal’s decision and the spouse’s permission should not be treated as identical events without assessment. A shared travel plan does not replace the relevant evidence.
Only after closing, because the qualifying relationship does not exist until ownership has actually transferred, and only once the transferee's one continuous year abroad falls within the prior three years. Recapture is arithmetic: days genuinely spent outside the United States during the L period do not consume the seven years, so careful travel records can return real months to an executive who has been crossing the border regularly. Establish one continuous full-time qualifying foreign year within the relevant preceding three years and determine the U.S. business stage before applying the ordinary rule. A first review produces a closing-to-filing checklist: completed ownership transfer, foreign payroll proof, U.S. operating evidence, and a duty chart.