J. Clifton Fleming Jr. (BYU; Google Scholar), Robert J. Peroni (Texas) & Stephen E. Shay (Boston College; Google Scholar), Viewing the GILTI Tax Rates Through a Tax Expenditure Lens, 177 Tax Notes Fed. 1525 (Dec. 12, 2022):

In this article, the authors explain that for U.S. corporations earning foreign-source active business income through controlled foreign corporations, pre-Tax Cuts and Jobs Act tax deferral planning is now largely obsolete and has been replaced with planning that centers on avoiding subpart F income and maximizing global intangible low-taxed income. They also explain that the low GILTI tax rates are a tax expenditure that fares poorly under cost-benefit analysis, even when taking into account the new U.S. corporate minimum tax and the possibility of modifications that would make the GILTI regime pillar 2 compliant.

Conclusion
Before the TCJA, the outbound income tax planning of U.S. MNEs was arguably focused on maximizing the subsidy provided by deferral of U.S. residual tax (particularly when combined with cross-crediting). The TCJA rendered deferral largely irrelevant and replaced it with strategies to maximize the amount of CFC income that qualifies for preferential tax rates provided by the GILTI regime. These rates are indisputably a tax expenditure that should be subjected to the same cost-benefit analysis that applies to direct government expenditures. This conclusion is not weakened by either the recently adopted U.S. corporate minimum tax or the possibility of the United States modifying the GILTI regime to make it pillar 2 compliant.

The GILTI rates fare poorly under cost-benefit analysis. They are defended principally as a subsidy to offset a broad international competitiveness challenge faced by U.S. corporations. However, the existence of that general problem is empirically unsupported, and if it exists, the GILTI rates are a poorly targeted remedy. More important, it seems unwise to divert revenue to trying to improve the international profitability of large U.S. corporations at the expense of other pressing U.S. needs.