Overview

The Trust will be an Ontario unit trust listed on the TSX. It will indirectly acquire interests in nine operating wind projects (with a purchase price of US$120 million) from US tax shelter investors - and expects to purchase further such interests. It will rely on not holding non-portfolio property; and on US co-investors in the wind projects not being considered to be investors in it for purposes of the US inversion rules.

Overview

The Fund will hold three apartment buildings, with a purchase price of U.S.$80.6 million, in Texas, through wholly-owned LLCs of Starlight U.S. Multi-Family Core REIT Inc. (the "U.S. REIT"), an indirectly owned Maryland corporation; and intends to make further acquisitions of apartment buildings in the southern US. It is issuing up to 7.5M units (allocated among different classes) for up to US$75M.

Overview

Overview

The Issuer, an Ontario LP, will hold 32 hotel properties, with an appraised value of $159.6M, in 19 states in the U.S. through American Hotel Income Properties REIT Inc. (the "U.S. REIT") and its subsidiaries. For FAPI purposes, this business is expected to be a services business rather than a property income business on general principles. It is issuing 10M units for $100M (assuming exercise of over-allotment option).

Structure

A TSX-listed mutual fund trust ("Trust) will hold, through a Canadian Holdco and a US Holdco, one third of the membership units, including a right (as managing member) to appoint the majority of directors, in a US LLC ("Crius Energy LLC" or the "Company"). The Company's business will be the sale of electricity and natural gas to retail and small commercial customers in the US.

A TSX-listed mutual fund trust ("Meranex"), through a Canadian Holdco, will hold a US Opco which will carry on a US oil and gas business, with the internal interest-bearing debt owing by US Opco directly to the Canadian Trust. Structure and tax disclosure are essentially identical to Argent Energy.

Structure

Basic structure

Brookfield Asset Management Inc. ("Brookfield Inc.) will distribute a portion of the LP units of the newly-formed BPY (a Bermuda LP) to its shareholders as a special dividend. BPY will hold most of its commercial real estate assets (mostly minority interests in various funds and companies located in various jurisdictions) through a subsidiary Bermuda LP ("Property LP").

A TSX-listed mutual fund trust ("Trust"), through a Canadian Holdco, will hold a US Opco which will carry on a US oil and gas business. Structure is similar to Eagle Energy, except that the US energy business is held through a Canadian holding corporation holding a US operating company rather than a Canadian sub trust holding a Delaware LP.

Canadian Tax

The Trust is not contemplated to be subject to SIFT tax on the basis that Can Holdco is a portfolio investment entity.

REIT subscriptions

REIT offering of 27M units at $10 per unit (with over-allotment option for 4M units) and $140M principal amount of convertible debentures - plus Dundee Corporation and Dundee Realty Corporation ("DRC") will purchase 12M units - for total net proceeds of perhaps $565M.