Recheck the actual placement before assuming the earlier L-1B arrangement remains appropriate.
Record the operational change
The offsite restrictions concern actual principal control and supervision or essentially labour-for-hire placement. Obtain a clear account of the changed duties and direction. Keeping the original contract unchanged does not erase a materially different working arrangement.
As soon as the planner's continuous year is documented and the customer contract or a signed letter of intent exists; allow for adjudication, premium processing if needed, and the possibility of a request for evidence on specialized knowledge. A work start date does not cure an arrangement where the unaffiliated employer principally controls and supervises the worker, or one that is essentially labor for hire rather than a product or service requiring knowledge specific to the petitioner. An internal title change usually does not restart the clock by itself, but the record must still contain one continuous year of qualifying work abroad within the three years preceding the relevant filing or admission analysis.
- 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
- L definitions, foreign employment and new-office evidence
- L1B specialized knowledge and offsite placement statute