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EB-1C · Multinational manager / executive (GC)

Convert an intracompany transfer into a green card via your US affiliate

EB-1C is for multinational managers and executives: at least 1 of the last 3 years in a managerial or executive capacity abroad, petitioned by a US affiliate that has been doing business for ≥ 1 year. No PERM, no self-petition.

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Eligibility

Who qualifies

  • Qualifying relationship between US and foreign entity (parent-subsidiary, branch, affiliate, joint venture) USCIS
  • 1 continuous year of employment at the foreign affiliate within the preceding 3 years, in a managerial or executive capacity USCIS
  • The US position must also be in a managerial or executive capacity (statutory definitions at INA §101(a)(44)) USCIS
  • The US entity has been doing business for at least 1 year (no shell or brand-new company) USCIS
  • Employer can document ability to pay: audited financials, tax returns, annual reports USCIS
  • US employer files the petition — EB-1C does not permit self-petition USCIS

Process

From intake to filing

Total duration
12–24 months (Premium Processing has been available for EB-1C I-140 since January 2023 — 45-day SLA)
Government fees
$715 (I-140) + optional $2,805 (Premium) + $1,440 (I-485, if concurrent)
AttorneyPetitionerApplicant
1
Phase 1
Case evaluation — three key elements → Collect qualifying-relationship evidence
Attorney
Petitioner
Applicant
1Case evaluation — three key elements

Evaluate three core elements: (1) qualifying relationship — ownership / control between US and foreign entities; (2) managerial or executive capacity — whether both foreign and US positions meet the statutory definition; (3) 1-year-in-3 — at least 1 continuous year at the foreign affiliate within the preceding 3 years.

Duration · 1–2 weeks

TipManager and executive are statutorily distinct. A manager directs professionals or an essential function; an executive exercises broad discretionary authority. A first-line supervisor of non-professional staff usually fails.
2Collect qualifying-relationship evidence

Collect qualifying-relationship documentation: articles of incorporation, corporate structure chart, board resolutions, stock-transfer agreements, joint-venture agreements. Both entities must be doing business. Pair with US operations evidence — office, employee roster, client contracts, revenue records.

Duration · 2–4 weeks

Articles of incorporation (US & foreign)Corporate structure chartBoard resolutionsCorporate tax returns+1
1Confirm qualifying relationship & business operations

Confirm the qualifying relationship (parent-subsidiary, branch, affiliate). Make sure the US entity is doing business (office, employees, clients, revenue). A newly established US entity must support the case with a comprehensive business plan and funding proof.

TipA brand-new US entity cannot file EB-1C — the statute requires the US employer to have been doing business for ≥ 1 year. Bridge with an L-1A new-office filing first.
2Establish organisational structure

Create a clear org chart showing the applicant's position and direct reports (must include professional-level employees or supervisors / managers). Describe each subordinate's duties to show the applicant need not perform day-to-day operational tasks.

1Confirm eligibility — 1 year abroad

Confirm at least 1 continuous year of managerial / executive employment at the foreign affiliate within the preceding 3 years. Collect: foreign-employment verification letter, pay stubs, social-insurance records, organisational chart.

Foreign-employment verification letterForeign payroll / social-insurance recordsForeign organisational chartForeign business card / appointment letter
2Describe foreign management duties

Describe foreign-side duties in detail: departments managed, number and hierarchy of subordinates, budget authority, decision scope. Emphasise management over operational work.

2
Phase 2
Draft Petition Letter — managerial / executive capacity → Prepare & file I-140
Attorney
Petitioner
Applicant
3Draft Petition Letter — managerial / executive capacity

Key arguments: (1) foreign position duties — scope, subordinate hierarchy, decision authority; (2) US position duties — org chart, number and titles of subordinates, applicant not performing day-to-day operational work; (3) for function-manager arguments, the essentialness and seniority of the managed function.

Duration · 2–3 weeks

TipThe single most common denial reason: US company too small (< 5 employees), forcing the applicant to perform operational tasks. Demonstrate sufficient staffing to handle day-to-day work.
4Prepare & file I-140

Complete I-140 (select EB-1C classification). Petitioner = US company. Compile the package: qualifying-relationship evidence, business-operations proof, organisational chart, managerial / executive capacity arguments, foreign-employment verification, ability-to-pay documentation.

I-140Petition LetterOrganisational charts (foreign & US)Offer Letter+4
3Issue key documents

Offer Letter (title, managerial / executive duties, salary, start date). Employer support letter (company overview, business description, why this executive is needed). Corporate tax returns, annual reports, or audited financials (ability to pay). Employee roster and payroll (company size).

Offer LetterEmployer support letterCorporate tax returns (last 3 years)Employee roster & payroll+3
4Coordinate foreign-company documents

Coordinate with the foreign affiliate to provide: registration documents, ownership structure proof, annual reports / financials, beneficiary's foreign-employment verification (appointment letter, payroll, org chart), and the foreign entity's employee count and business scope.

3Understand US position duties

Get familiar with the US-side duties and org structure. Confirm your US role is also managerial / executive — leading a team or essential function — and that the Offer Letter matches reality.

4Review application materials

Review the Petition Letter and all forms prepared by counsel. Confirm: foreign-experience description is accurate, management duties are neither overstated nor dropped, company-relationship description is correct, personal data is right.

3
Phase 3
RFE response → I-485 / consular processing
Attorney
Petitioner
Applicant
5RFE response

Common RFEs: (1) US company too small to support the role; (2) qualifying-relationship evidence thin; (3) function-manager definition disputed; (4) continuity of the 1-year foreign experience; (5) ability-to-pay shortfall. Be ready with supplemental org charts, payroll, and business-growth plans.

6I-485 / consular processing

After I-140 approval, check the EB-1 visa bulletin. If current, file I-485 in the US or DS-260 abroad. Otherwise wait. China- and India-born applicants may face a 1–2 year backlog.

5Ongoing obligations during I-485

Keep the position available during I-485 adjudication. Notify counsel of any structural change (merger, reorganisation, headcount swings). Maintain business operations and ability to pay.

5I-485 adjustment of status

After I-140 approval: (A) file I-485 + I-765 (EAD) + I-131 (AP) in the US, complete medical exam and biometrics; (B) consular processing abroad. Maintain valid status (typically L-1A) while waiting.

TipIf you hold L-1A and your EB-1C I-140 has been pending ≥ 1 year, AC21 §106(a) allows L-1A extensions beyond the 7-year cap.

Documents

What you need to prepare

Filed by the US employer as petitioner. Select the EB-1C classification.

US-employer ability-to-pay evidence

Audited financials, the last 3 years of corporate tax returns, and annual reports — proving the employer can pay the offered wage.

Organisational charts (foreign + US)

Showing the applicant's position on both sides, direct reports, and their reports — to evidence a managerial / executive (not operational) role.

Managerial / executive duties memo

Maps the foreign and US duty descriptions to the statutory definitions in INA §101(a)(44).

Payroll & personnel records

Employee roster, W-2s, pay stubs, hire / termination records — establishing company size and ongoing operations.

Foreign affiliate continued-operations evidence

Foreign-company registration, annual reports, recent financials — proof the foreign entity is still doing business.

Foreign-employment verification letter

Issued by the foreign affiliate — covers start date, title, managerial / executive duties, salary, reporting line.

Offer Letter (US position)

Title, managerial / executive duties, salary, start date — aligned with the Petition Letter.

Qualifying-relationship evidence

Cap table, board resolutions, stock-transfer agreements, joint-venture agreements — establishing parent-subsidiary / branch / affiliate ties.

Concurrent with I-140 when the priority date is current; otherwise wait for the bulletin.

EB-1C I-140 has been eligible for Premium Processing since January 2023 — $2,805 for a 45-day SLA.

Signed by the attorney of record.

Timeline

Stage-by-stage durations

StageDurationWhat can go wrong
Case evaluation · qualifying relationship + capacity1–2 weeksEither side still a shell or not operating — any of the three core elements missing kills the case outright.
Evidence collection & org-structure work4–8 weeksOrg chart too thin to support a managerial role — the officer concludes the applicant is really an operator in a manager's title.
Draft Petition Letter (capacity argument)2–3 weeksA first-line supervisor of non-professional staff does not meet the statutory definition of managerial capacity, no matter the title.
File I-140 · adjudicationStandard 6–12 months · Premium ≤ 45 days (Premium opened January 2023)Managerial-capacity RFEs are stricter in EB-1C than L-1A — Premium just delivers the RFE sooner.
I-485 or consular processing (once priority date is current)6–18 monthsEB-1 backlogs of 1–2 years are common for China- and India-born applicants — the I-140 receipt date locks the priority date immediately.

FAQ

Things people ask us

EB-1C vs L-1A — what is the actual difference?

L-1A is a non-immigrant work visa (temporary status, capped at 7 years total). EB-1C is an immigrant petition — the green-card track. The underlying tests are nearly identical (qualifying relationship, 1-year-in-3, managerial or executive capacity), which is why L-1A → EB-1C is the standard sequence. But EB-1C is adjudicated more strictly, especially on company size and whether the role is truly managerial. Most cases that pass L-1A still need a sharper capacity argument to pass EB-1C.

Can I go straight to EB-1C without holding L-1A first?

Legally yes — there is no statutory requirement to have held L-1A. The core EB-1C tests are about the foreign employment (1 of the last 3 years) and the US entity's ≥ 1-year operating record, not your prior US status. In practice it is uncommon: most applicants are already in the US on L-1A because the requirements overlap and the bridge gives the US entity time to mature. Filing directly from abroad and proceeding via consular processing is viable when the US entity is already well established.

How is the "1 year in the last 3" counted?

It must be one continuous year (not 12 months aggregated across multiple stints) at the foreign affiliate, in a managerial or executive capacity, within the 3 years immediately preceding the I-140 filing — or, for applicants already in the US on L-1A, the 3 years preceding the initial L-1A entry. Time spent on US assignment for the same employer pauses the clock but does not count toward the 1 year. Sabbaticals, leaves of absence, and time at unaffiliated companies all break continuity.

Is Premium Processing available for EB-1C I-140?

Yes — USCIS extended Premium Processing to EB-1C I-140 in January 2023 (it was excluded for years). The current fee is $2,805 for a 45-day SLA: USCIS must issue an approval, denial, or RFE within 45 days. Premium does not improve odds; on EB-1C specifically, where managerial-capacity RFEs are common, you may want to lock the petition tightly before paying for a faster RFE.

I was born in mainland China — how bad is the EB-1 retrogression?

EB-1 for China-born and India-born applicants has been retrogressed roughly 1–2 years behind current since 2022, per the monthly DOS Visa Bulletin. The priority date is set when USCIS receives a complete I-140, so the cheapest hedge is to file the I-140 as soon as the package is defensible — even if you intend to wait on I-485. Country of birth (not citizenship or residence) controls the queue.

What happens to my L-1A 7-year cap if EB-1C is still pending?

AC21 §106(a) lets you extend L-1A in 1-year increments beyond the 7-year cap if your EB-1C I-140 has been pending for at least 1 year (or has been approved but your priority date is not yet current). This is the standard mechanism that keeps China- and India-born EB-1C applicants in status during retrogression. File the I-140 well before the L-1A 7-year mark to have the 1-year-pending clock available when you need it.

Can a US employer with less than 1 year of operations file EB-1C?

No. The statute requires the US entity to have been doing business for at least 1 year before the I-140 is filed. The standard workaround is an L-1A "new office" filing first — L-1A allows new offices with a strong business plan, then after 12 months of actual operations the US entity is eligible to petition the EB-1C. Trying to file EB-1C earlier results in denial; this is not a discretionary requirement.

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