Brookfield Infrastructure Partners L.P. is issuing preferred units with distributions thereon to be 50% tax-deferred

Brookfield Infrastructure Partners L.P., which is a TSX- and NYSE-listed Bermuda limited partnership, is issuing preferred units (to be TSX-listed) with attributes similar to the preferred units that have been issued by REITS, such as Artis.  These prefs likely will be allocated the same percentage of income for ITA purposes (expected to average around 50% for the next five years) as on the "common" units.  Where a pref holder also holds common units, the LP considers it to be reasonable for the holder’s ACB to be allocated between its prefs and commons as if they were separate types of property rather than identical property (see also 2014-0538161C6).

The LP's general partner is intended to have Bermuda central management and control so that the LP can avoid SIFT taxation. Part XIII tax withheld on dividends paid by indirect Canadian subsidiaries of the LP will take into account the residency status (i.e., Canada, Treaty- and non-Treaty countries) of the LP partners (which is not a trivial undertaking for a publicly traded LP).

For U.S. purposes, the LP does not expect to withhold US taxes from the pref distributions on the basis inter alia that they are guaranteed payments for the use of capital, rather than the holders being subject to the more usual partnership taxation rules.

Neal Armstrong.  Summary of Brookfield Infrastructure Partners L.P. prospectus for offering of preferred units under Offerings - REIT and LP Offerings - Preferred Unit Offerings - Limited Partnerships.