Final regulations under Internal Revenue Code1 Section 951A (TD 9902), which were published in the Federal Register on 23 July 2020, implement an elective exclusion for high-tax global intangible low-taxed income (GILTI). Proposed regulations under Section 954 (REG-127732-19), which were published simultaneously with the final regulations, propose changes to the existing subpart F income high-tax exception under Section 954(b)(4).The final GILTI high-tax exclusion:Excludes from a controlled foreign corporation's (CFC) gross tested income under Section 951A income items subject to an effective foreign tax rate over 18.9% (i.e., 90% of the highest corporate rate based on the current 21% corporate tax...