No. The nature of the positions and your actual managerial duties matter; individual educational attainment alone does not establish the case.
Examine the jobs being supervised
Show the professional work and relevant job requirements, together with your authority and duty allocation. An ordinary first-line supervisor does not become a qualifying manager simply because staff members have degrees. The qualifying organizations, continuing business and foreign-employment conditions must also be established.
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. Supervising employees who are neither supervisors, professionals nor managers is first-line supervision, which the statute excludes from managerial capacity unless the person manages an essential function of the organization at a senior level. 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.