Not until a continuous qualifying year abroad exists within the applicable window. Filing early on an optimistic count risks a denial that costs more than the delay, and the timeline should be verified on documents before a date is promised.
Establish the earliest lawful filing date first
The productive way to handle this is to treat the earliest lawful filing date as an output of the timeline rather than an input to the plan. Once the month-by-month record exists and has been reviewed, that date is known, and everything else can be scheduled around it: the subsidiary's premises, hiring, the position description, and the family's arrangements. Where the date is further out than the business would like, the intervening months are not wasted, because corporate evidence, the business plan and the organizational design all improve with attention. What does not work is choosing a filing date commercially and then asking whether the employee qualifies, which is how companies end up arguing a position they could have avoided by waiting a few months.
Hypothetical example: Imani manages a Canadian medical-device wholesaler that will open a U.S. branch next year. Her first review should identify the earliest date on which the foreign employment year is complete, the filing lead time, and the deadline by which the U.S. role must be supported. Payroll dates settle the first point; the premises, hiring plan, and business records settle the last. She should not promise customers that she will be onsite before the petition process allows it. For a new office, the first year is a measurement period, so hiring and revenue milestones need owners and dates from the beginning.