Speaking as a semanticist, it's wild to me that they are phrasing it in terms of whether an *act* is characterized as "official", when what they seem to actually be talking about is whether there exists a *description* of the act that can be characterized as "official".
Wouldn't one just potentially go straight to the Office of Legal Counsel, ask for them to declare X to be an official act, then do it. And then of course, because you control the OLC as POTUS, you staff the OLC with people who will say yes, obviously official act.
