If there are two Puerto Rico employees who are eligible to defer in a US -based 401(k) plan, when testing the Puerto Rico part of the plan, do you have 0 or 1 HCE (1/3 of 2 is .6667)?
I thought that you rounded to the nearest integer, so if there are at least 2 Puerto Rico employees, you will always have at least 1 HCE.

???