UCITS ("Undertakings for Collective Investment in Transferable Securities") are a type of collective investment vehicle and, like many collective investment vehicles, they may be difficult to fit into existing tax and regulatory schemes. Although UCITS were developed to facilitate cross-border investments, including resolving possible tax issues, the model U.S. and model OECD treaties are only recently beginning to effectively address collective investment vehicles. In addition, the U.S. regulatory scheme for securities limits the way UCITS sponsors may offer UCITS securities in the U.S.
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