Brookfield/BBP LP -- summary under Foreign Asset Income Funds and LPs

Summary Under
Tax Topics - Public Transactions - Offerings - REIT, Trust and LP Offerings - Foreign Asset Income Funds and LPs
Brookfield Asset Management is spinning off Brookfield Business Partners, L.P. as a taxable dividend

Overview. Brookfield Asset Management, which is a Canadian-resident corporation listed on the NYSE, NYSE Euronext and TSX, will distribute the (non-voting) LP units of BBP LP to its shareholders as a special dividend, with such distribution being referred to as the spin-off. Brookfield Asset Management will retain an approximate 70% economic interest in the business by virtue of holding approximately 45% of the units of BBP LP directly and by virtue of holding an approximate 45% partnership interest in Holding LP, which will be the subsidiary LP of BBP LP. Holding LP will be Brookfield's primary vehicle for business services and industrial operations, with most of those businesses held (indirectly) outside Canada. BBP LP will apply for TSX and NYSE listings.

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Tax Topics - Public Transactions - Spin-Offs & Distributions - Taxable dividends-in-kind - Subsidiary distribution Brookfield Asset Management spin-off of Brookfield Business Partners, L.P. as a taxable dividend 1393