Yes, as evidence of the subsidiary's substance and its ability to pay the transferee, but not as an investment claim. The transfer routes do not have an investment test.
The purchase is evidence, not a qualification
Confusing the transfer route with the investor route leads companies to lead with the money. The classification asks about corporate relationships and duties; it never asks how much was invested. What the purchase price and the financing do support is a different point that the petition genuinely needs: that the American entity has the financial ability to pay the transferee's salary and to sustain a managerial role, and that it is a real operating business rather than a shell. So include the closing statement, the opening balance sheet, the payroll registers and the bank statements, and describe them as evidence of capacity. Keep immigration filing costs out of the business figures entirely, and take those amounts from the current official fee schedule at the time of filing.
Hypothetical example: a modular-kitchen manufacturer purchases a small American assembler and budgets only for acquisition expenses. A first review separates transaction costs, petition fees, professional fees, payroll and the funds needed to build the U.S. management structure. Bank records, closing papers and cash-flow projections settle whether the entity can support the position. If the projections show that the transferee must spend every day assembling cabinets to keep the business afloat, the company must revise the staffing plan or reconsider the filing. A managerial petition should not rely on a payroll model that contradicts its proposed duties.
- USCIS — L-1A intracompany transferee executive or manager
- USCIS Policy Manual — L-1 evidence (Vol. 2, Part L, Ch. 8)
- 8 CFR 214.2(l) — intracompany transferees
- 8 U.S.C. 1101(a)(44) — managerial and executive capacity
- USCIS Policy Manual — employment authorization for certain spouses
- USCIS — fee schedule (G-1055)