No. Principal control and supervision require the actual arrangement to be assessed, alongside the separate labor-for-hire limitation.
Look beyond payroll
Identify who directs the work and how it connects with the petitioner’s product or service.
Begin with the organisation's actual quality system: its documentation hierarchy, the internal specifications that go beyond the standard it is certified against, its supplier controls, and the way it handles deviations. L-1B requires specialized knowledge of the petitioner's own product, processes or procedures; general programming competence available in the labour market does not qualify. The analysis concerns whether the employee has qualifying special or advanced company knowledge and whether the proposed U.S. duties actually require it, assessed on the complete evidence presented. Customer familiarity may support the knowledge narrative, but it cannot become payroll service retroactively or turn general industry skill into company-specific knowledge. Keep training costs separate from current government fees and professional review, and avoid spending on credentials that do not explain the actual special or advanced knowledge.
- USCIS — L classification documentation and evidence
- Department of State — 9 FAM 402.12
- 8 USC 1184 — specialized knowledge definition
- USCIS — employment authorization for certain spouses
- ICE — nonimmigrant classes that may study
- USCIS — fee schedule
- Official regulatory L foreign-capacity and new-office standards