Not necessarily. Assess the actual duties as a whole and who performs the operational tasks.
Avoid a selected snapshot
A short list of approvals may not describe what the person mainly does.
Managerial capacity means managing the organization, or a department, subdivision, function or component of it; supervising other supervisory, professional or managerial employees or managing an essential function; holding authority over personnel decisions or functioning at a senior level; and exercising discretion over day-to-day operations. Ownership can help explain the corporate relationship, but the qualifying foreign employment, a parent, branch, subsidiary or affiliate relationship, both the foreign and U.S. entities remaining active, and a primarily managerial or executive U.S. role still need independent evidence. The regulation asks whether the position is primarily managerial, which in practice means the greater part of the transferee's time is spent directing people or an essential function, setting goals, and exercising authority over hiring, discipline and resources. If the answer is managing schedules, negotiating with distributors, approving quotes, hiring a second crew and reviewing the subsidiary's financial results, the role is managerial and the number of subordinates matters less than the level of authority.