USCIS issued a policy memorandum clarifying that to establish a qualifying relationship for an L-1 visa petition where the petitioner has submitted documentation of control by proxy votes, the petitioner must show that the proxy votes are irrevocable from the time of filing the L-1 petition through the time of adjudication. If ownership and control of the organization changes after USCIS adjudicates the petition, the petitioner must file an amended petition. The memo includes an update to the Adjudicators Field Manual and is effective immediately.
Source: AILA Doc. No. 18010463.