According to the n4296 C++ standard document:
[dcl.init.list] (8.5.4.4) (pg223-224)
Within the initializer-list of a braced-init-list, the
The answer seems to be that yes, this is a bug in both GCC and MSVC.
This is the status of this issue:
My personal investigation, discussions with C++ experts at conferences, and unofficial answers I've received from compiler developers indicates that this is a bug in MSVC and GCC, but I'm always reluctant to answer my own questions on StackOverflow. But here we are.