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Plan sponsors both a US and a Puerto Rico plan (not dual-qualified but separate plans). I have an HCE that worked for both companies during 2015 and participated in both plans.

Does mandatory HCE aggregation apply? In other words, if both plans were US plans (assuming part of the same controlled group) and the HCE was eligible and participated in both plans, I would be required to aggregate their comp/contributions under both plans and test the total in both plans. Is this a requirement if US vs Puerto Rico plan?

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