Puerto Rico Company Wants to Set Up Cafeteria Plan for its Continental US Employees

[401 Chaos]

Is is possible for an entity incorporated in Puerto Rico (and/or controlled group of PR corporation) to establish a Code Section 125 cafeteria plan for its employees in the continental US.  The vast majority of employees of the controlled group are located in Puerto Rico and so generally wouldn't be expected to pass the eligibility  or benefits test if a cafeteria plan must count all employees within the group for testing purposes as the PR employees are not generally eligible or able to benefit from the cafeteria plan under current PR law as I understand it.  I'm not sure if there is any sort of SLOB or similar workaround that may be commonly attempted in these situations.  Thanks