Can you elaborate on this? I tend to use emacs exclusively in the terminal, since I'm often using them on remote workstations. For remote workstations, I can (a) open files using TRAMP, (b) open a remote GUI with X11 forwarding over SSH, or (c) open a remote TUI. TRAMP doesn't always play nicely with LSP servers, and remote TUIs are much, much more responsive than X11 forwarding.
Locally, the performance of emacs depends far more on the packages I load than on the GUI vs TUI, so I'm interested in hearing what overhead there would be.