The United States Department of the Treasury decided against signing the 2016 OECD anti–BEPS MLI initiative from the § Failure of OECD (2012–2016), stating that the U.S.: "has a low degree of exposure to base erosion and profit shifting".[1] International tax academics showed in 2018 that U.S. multinationals are the largest users of BEPS tools in the world;[2] while U.S tax academics demonstrated,