From No U.S. Income to U.S. Income

[Nate X]

A follow up to this discussion

http://benefitslink.com/boards/index.php/topic/35611-hce-determination-question/

It appears that 414(q)(8) only determines if a person is considered an employee for HCE determination. So if a person begins having U.S. Income in mid-2016, they are considered an employee for plan purposes. 414(q)(1)(B) says, "For the preceding year (i) had compensation from the employer in excess of $80,000, and..."

What are your thoughts on including the non-resident alien's income earned outside the U.S. with the same company for the purpose of 414(q)(1)(B) for 2015 and 2016?