Scope of Plan Aggregation

[SycamoreFan]

I'm familiar with the categories of plans for the purposes of plan aggregation, however, I have a question regarding the scope of plan aggregation with respect to non-qualified stock options. As I understand it, the plan aggregation rules under Section 409A provide that deferrals of compensation with respect to an employee, to the extent such plans are stock options or stock appreciation rights subject to Section 409A, are aggregated and treated as if deferred under a single plan.

I'm trying to clarify what exactly that means with respect to other stock option grants to the same employee. For example, ABC company grants employee Z a non-qualified stock option that is granted with an exercise price below grant date fair market value. That NQSO would be subject to Section 409A. For the purpose of income inclusion, would that stock option be aggregated with: (1) all other stock option grants to employee Z from ABC company, or (2) only the stock options granted to employee Z that are subject to Section 409A because they were granted with an exercise price less than grant date fair market value, or similar failure to comply with Section 409A?