Possibly, as a function manager, but the petition must show the function is essential to the organization and that she manages it at a senior level with discretion over policy. A manager of people with subordinate supervisors or professionals is the more straightforward case.
People manager or function manager, proven differently
Hypothetical example: the U.S. subsidiary plans for the New Maryland director to build the customer-success team from scratch and has not yet hired anyone under her. L-1A covers managers who supervise professional or supervisory staff and also managers of an essential function, but the function-manager route needs evidence that the function is a core one, that she sets its policy and that she does not primarily perform the day-to-day tasks herself.
If the team will not exist for months, the sequence should change: either hire the first team leads before filing so that she manages people from day one, or build the petition around an essential function with a hiring plan and accept closer scrutiny. In either case she still needs one continuous qualifying year abroad within three, the companies must be related and operating, and the seven-year limit applies. The first review should produce a date chart for foreign employment, ownership, and the intended U.S.
role, together with a map of who will be managed. Payroll and reporting records usually settle the foreign-service question; the proposed organization chart and job description settle whether the new role is managerial or executive. Hypothetical example: a museum-services company wants to transfer its curator of travelling exhibits to lead a U.S.
division. The reviewer distinguishes hands-on exhibit installation from authority over programme managers, budgets, and vendor policy, then asks the company to document the latter. That discipline matters because seniority in a title does not by itself establish the required capacity.