Explain the actual dates and responsibilities and identify the records supporting that account. A difference between the effective duty change and formal title can be legitimate, but it should not be invented to improve eligibility. Preserve documents that show the history rather than making all dates identical.
Use corroboration where available
Organization records, project authority, personnel decisions or other relevant evidence can help explain the role. Choose material that addresses the claimed responsibilities. A retrospective letter can provide context, but a conclusory statement that the applicant was always a manager leaves the substantive question unresolved.
The group knows perfectly well that it will own both, but a petition is decided on records: share registers, the purchase agreement and its closing documents, resolutions appointing directors, and financial statements showing each company regularly and systematically providing goods or services. An organizational chart dated to the proposed start, a staffing plan with headcount and hire dates, a lease or service agreement showing the operation exists as described, and the foreign payroll register covering the qualifying year each answer a distinct question. For trading, the American side needs to look like a working business rather than an acquisition on a balance sheet: recent payroll registers, current service agreements with turbine owners, issued invoices, lease or premises documents and a filed federal return.