From a UK perspective seems strange that any investment company would it self owe CT tax individual US shares don't. And the USA does have REIT's as a model.

From a UK perspective seems strange that any investment company would it self owe CT tax individual US shares don't. And the USA does have REIT's as a model. And large chunks of the capital invested in the USA in the 19th century was by UK investment trusts which don't pay capital gains - the owner of the shares does.