A consulting firm L-1A petition faces a direct version of the executive-vs-operational tension: if the beneficiary is the one actually delivering the consulting work to clients, that is professional/operational work, not managerial — regardless of how senior or well-compensated the role is.
Managing Delivery, Not Delivering Personally
The strongest L-1A consulting plans show the beneficiary managing a team of consultants who deliver client work, with the beneficiary responsible for business development, client relationship oversight at a strategic level, and managing the practice — not billing hours on engagements personally.
Staffing Plan as the Core Evidence
A credible plan needs specific consultant and analyst hires who will deliver the actual client work, reporting to the beneficiary. Without these hires (or a credible plan to make them early), the petition risks looking like a solo practitioner using an executive title.
Qualifying Relationship and Practice Area
Tie the US consulting practice to the foreign entity's established expertise and client base — is this the same practice area extending into the US market, serving US subsidiaries of existing foreign clients, or a genuinely new but related practice? This context matters for both the qualifying relationship and the business rationale.
Month 12 Checkpoint
By the extension filing, real consultants should be in place delivering client work, with the beneficiary managing the practice and client relationships at a senior level — this is the concrete change the extension petition needs to demonstrate.
This is a draft for your attorney's review before filing — not a legal document itself, and no outcome is ever guaranteed.