J. Clifton Fleming (Brigham Young University - J. Reuben Clark Law School), Robert J. Peroni (The University of Texas School of Law), & Stephen E. Shay (Boston College Law School) have posted The U.S. Tax System's Curious Embrace of Manufacturing Job Losses on SSRN. Here is the abstract:
In this article, the authors explain how the subpart F regime and the global intangible low-taxed income regime together contribute to a long-running decline in domestic manufacturing employment, and they argue that the best approach to fixing the problem is worldwide taxation without deferral, not pillar 2.