Bret Wells (Houston; Google Scholar), The Enigma of BEPS, the United States, and Global Tax Cooperation:

The OECD frequently lauds its Pillar 2 project as a cooperative global effort to ensure that large multinational enterprises pay a minimum tax regardless of where they are headquartered and regardless of the jurisdiction where their operations are located. The United States and at least 137 other nations have all agreed that global tax cooperation is consistent with their fiscal interests and their fiscal priorities. However, it is at this point that one should remember the admonition that “the devil is often in the details.” This paper attempts identify those areas where the Pillar 2 model rules are deficient and where further reforms to the GloBE rules are necessary to ensure achievement of the agreed-upon aspirational goal. …

With reform, perhaps the OECD Pillar 2 model rules could evolve towards a workable global agreement that imposes an actual minimum tax that tax competition cannot supplant, but until then the United States and other like-minded nations should address the tax competition design deficiencies in the OECD Pillar 2 model rules through unilateral options that protect their own fiscal interests given that tax competition and profit shifting to low-tax environs remains a pernicious reality under the OECD Pillar 2 model rules.