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FOR BUSINESS LEADERS · RICHMONDRichmond

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A reorganisation that closes midway through preparation can invalidate half a packet quietly. Entities merge, a holding company is inserted, reporting lines move, and documents assembled two months earlier describe a structure that no longer exists. This illustrative discussion sets out how to track the change, what has to be refreshed, and how the household, budget and sequence should respond. Hypothetical example: an aircraft parts distribution group inserts a new holding company and merges two subsidiaries while a transfer file is being assembled. Nothing about the manager's work changes, yet the entity that employed him abroad and the entity that will employ him in the United States are now connected differently. L classification depends on a qualifying parent, branch, subsidiary or affiliate relationship, so that connection is the case.

Talk about L-1A
PurposeExecutive or managerial transfer
Company linkQualifying related businesses
New officeA distinct evidence requirement

IN THIS GUIDE · Keeping ownership and reporting evidence accurate while a group reorganisation is under way

Start with the L-1A eligibility and application overview

01

Map the structure before and after

Draw two ownership charts: the group as it stood when the plan was made, and the group as it will stand when the change completes. Show percentages, intermediate entities and the legal names on each. The qualifying relationship for an L case runs on parent, branch, subsidiary or affiliate connections, so the reviewer needs to see which entity employed the person abroad, which will employ them, and how the two are linked after the reorganisation. Date both charts and name their source. A chart drawn from a registry extract carries weight that an internally produced diagram does not, and a reviewer comparing two documents will notice which one has a provenance. Where a jurisdiction's register lags, note the lag rather than presenting a stale extract as current.

02

Fix the closing date and work from it

Ask corporate counsel for the expected completion date and the conditions still outstanding, then mark every document already gathered with the structure it assumes. Anything describing the old chart is provisional. Keep the reorganisation's own paperwork, including share transfer agreements, resolutions and amended registers, because those documents are the bridge between the two charts and answer the question of how the group got from one to the other. Completion dates move, so record what would cause this one to move and by how much. A consent from a regulator behaves differently from a signature awaited from a shareholder, and the plan should be able to say which kind of delay is in play. That distinction is also what allows a realistic answer when the business asks whether to hold the filing.

03

Refresh the reporting picture, not just the ownership one

Reorganisations move people as well as shares. A manager who directed six staff in one division may direct three in another once functions are consolidated, and a duty statement written before the change can overstate the role by accident. Redraw the organisational chart around the person as it will be after completion, name the subordinates and their functions, and have the new reporting executive confirm it in writing. A managerial or executive position is a defined description rather than a level of seniority, so the redrawn chart should show what the person will actually direct: functions, subordinates or a component of the organisation. Where consolidation has reduced that scope, say so and take advice, because a duty statement that survives a reorganisation unchanged is usually a duty statement nobody reread.

04

Decide whether to file across the change or around it

Bring both charts and the closing date to licensed US immigration counsel and ask which employing entity the case should name, whether to file before or after completion, and what happens if the structure changes again while a filing is pending. Also ask what notification obligations may arise from a change of employer. Then set a rule internally: no document goes into the packet without the date of the structure it describes. Add one further question for counsel: what evidence would be needed if the structure changed again after filing. Groups that reorganise once often reorganise twice, and knowing in advance which documents would have to be refreshed turns a second change from a crisis into a task. Record the answer with the file rather than in an inbox.

SOURCES FOR THIS GUIDE

Sources reviewed 2026-09-07. This guide covers a preparation focus; it is not an individual eligibility assessment.

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