A GILTI High-Tax Exclusion Election Would Erode the U.S. Tax Base. Stephen Shay, November 18, 2019, Paper, “This article responds to the Notice of Proposed Rulemaking under Sections 958 and 951A published in the Federal Register on June 21, 2019 (the “Proposed Regulations”).1 The proposed expansion of the high tax election should not be adopted for the reasons set out in this article, including most importantly that the statute does not provide a basis for the interpretation proposed to be adopted.Link