General Shareholder Tax Summary
The following discussion is intended to provide a general explanation of the U.S., Canadian, European, and Australian tax treatment of holding Brookfield Business Corporation shares.
This summary is of a general nature only and is not intended to be, nor should it be construed to be, legal or tax advice to any particular holder of Brookfield Business Corporation shares, and no representation with respect to the U.S., Canadian, Australian and European income tax consequences to any particular holder is made. Consequently, holders of Brookfield Business Corporation shares are advised to consult their own tax advisors with respect to their particular circumstances. For a detailed discussion of the material tax considerations for unitholders relating to the special distribution of class A shares and of the ownership and disposition of class A shares, please refer to our SEC Form F-1 Registration statement.
Information | 2023 | 2022 |
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Withholding Tax Information for Dividends | Withholding Tax Information for Dividends 2023 | Withholding Tax Information for Dividends 2022 |
What is the tax nature of the distributions paid by Brookfield Business Corporation?
Brookfield Business Corporation expects to pay eligible dividends to its shareholders.
I am a Canadian resident. Is the dividend I am paid from Brookfield Business Corporation subject to withholding tax?
Dividends paid from Brookfield Business Corporation to Canadian resident shareholders are not subject to withholding tax.
Is the dividend I am paid from Brookfield Business Corporation considered an “eligible dividend”?
For purposes of the enhanced dividend tax credit rules contained in the Income Tax Act (Canada) and any corresponding provincial and territorial tax legislation, all dividends (and deemed dividends) paid by Brookfield Business Corporation to Canadian residents and unless stated otherwise, are designated as "eligible dividends".
Is Brookfield Business Corporation eligible for Tax-Deferred Plans?
Brookfield Business Corporation is a qualified investment for registered retirement savings plans, deferred profit-sharing plans, registered retirement income funds, registered education savings plans, registered disability savings plans and tax-free savings accounts.
What Tax Form will I receive as a Canadian shareholder?
Form T5 – Statement of Investment Income will be issued to Canadian resident shareholders. Form T5 contains information about investment income from Brookfield Business Corporation.
Who will send my Tax Form (T5)?
Unregistered Canadian resident shareholders (i.e., those holding their shares in street name with their brokerage) who own their shares in a non tax-deferred account should receive a T5 from their Canadian broker. If you are a beneficial Canadian resident shareholder and did not receive your Form T5, please contact the brokerage firm with whom your shares are held.
Registered Canadian resident shareholders will receive a T5 directly from our transfer agent TSX Trust Company. If you are a registered Canadian resident shareholder and did not receive your Form T5, please contact TSX Trust Company toll-free at 1-877-715-0498 or direct dial at 1-416-682-3860.
When will I (non-registered shareholder) receive my Tax Form (T5)?
Typically, brokers will prepare and distribute the Form T5 by the end of February. If you have any questions about Form T5 you should contact your broker.
Why does the $CAD cash I received not equal the amount reflected on my T5?
The dividends you receive adjusted for foreign exchange rates should equal the investment income reported on Form T5. There may be minor differences due to exchange rates.
Is Brookfield Business Corporation a Specified Foreign Property?
Brookfield Business Corporation is not a Specified Foreign Property and therefore does not need to be reported on Form T1135 Foreign Income Verification Statement.
What is the Adjusted Cost Base (“ACB”) of my shares?
In general, a shareholder's tax cost or ACB of their Brookfield Business Corporation shares should equal the amount paid to acquire the shares.
I owned units of Brookfield Business Partners L.P. prior to the formation of Brookfield Business Corporation. As a result of the special distribution from Brookfield Business Partners L.P, I received class A shares of Brookfield Business Corporation. Is this special distribution taxable for Canadian federal income tax purposes?
The special distribution should not be taxable to a Canadian resident shareholder for Canadian income tax purposes provided the adjusted cost base of the Brookfield Business Partners L.P units held by the Canadian resident holder is positive after the special distribution.
In general, this special distribution will reduce the adjusted cost base of your interest in the partnership units of Brookfield Business Partners L.P. by an amount equal to the fair market value at the time of the special distribution of the Class A shares you have received. The same fair market value at the time of the special distribution of the Class A shares received is your adjusted cost basis. The opening price of a share of Brookfield Business Corporation on the New York Stock Exchange on March 15, 2022 was $27.75.
I understand I can exchange a class A share of Brookfield Business Corporation for a unit of Brookfield Business Partners L.P. What are the tax consequences to a Canadian shareholder as a result of this exchange?
The exchange would be considered a disposition of the class A share of Brookfield Business Corporation. A Canadian resident shareholder who disposes of a share of Brookfield Business Corporation, will realize a capital gain (or sustain a capital loss) equal to the amount by which the proceeds of disposition exceed (or are exceeded by) the aggregate of the shareholder’s adjusted cost base of such share and any reasonable costs of disposition.
These questions and answers are for general information purposes only and are not legal or tax advice. Brookfield does not provide legal or tax advice. Please consult your own tax adviser regarding your personal tax circumstances.
What is the tax nature of the distributions paid by Brookfield Business Corporation?
Dividends paid by Brookfield Business Corporation are expected to be eligible for “qualified dividend” treatment, provided that certain requirements are met. Among other things, the shareholder must meet a holding period requirement, and Brookfield Business Corporation must not be a passive foreign investment company.
Is Brookfield Business Corporation considered a passive foreign investment company ("PFIC")?
Based on the current and anticipated income, assets and operations of Brookfield Business Corporation and its subsidiaries, Brookfield Business Corporation does not expect to be a PFIC for U.S. federal income tax purposes for the current tax year or future tax years. However, the application of the PFIC rules is uncertain, and a separate determination must be made after the close of each tax year as to whether Brookfield Business Corporation is a PFIC for that year. Changes in the composition of Brookfield Business Corporation's income or assets may cause it to become a PFIC. Accordingly, there can be no assurance that Brookfield Business Corporation will not be a PFIC for any tax year.
I am a U.S. resident. Is the dividend I am paid from Brookfield Business Corporation subject to withholding tax?
Dividends paid by Brookfield Business Corporation to a U.S. resident shareholder may be subject to Canadian withholding tax. The rate of withholding can range from 0% to 25%. The rate depends, among other things, on the type of ownership account, and whether the holder has provided his or her broker (or our transfer agent in the case of a registered shareholder) with the appropriate Canada Revenue Agency Form NR301, NR302, or NR303 whichever applies).
Which U.S. tax form will I receive as a U.S. shareholder?
Dividends paid by Brookfield Business Corporation are reported annually on IRS Form 1099-DIV, which is generally made available to shareholders in February.
I owned units of Brookfield Business Partners L.P. prior to the formation of Brookfield Business Corporation. As a result of the special distribution from Brookfield Business Partners L.P, I received class A shares of Brookfield Business Corporation. Is this special distribution taxable for U.S. federal income tax purposes?
Although the special distribution itself is generally expected to be tax-free, certain transactions preceding the special distribution are expected to be taxable. As a result of these transactions, each U.S. unitholder generally is expected to recognize taxable dividend income equal to the value of the class A shares received (plus the amount of any cash received in lieu of a fractional share and the value of the exchange rights associated with the class A shares received). In addition, because no cash will be distributed in the special distribution (except for cash in lieu of fractional shares), U.S. unitholders generally will need to satisfy any resulting U.S. tax liability from their own funds, including, for example, by selling a portion of the class A shares received in the special distribution.
I exchanged a class A share of Brookfield Business Corporation for a unit of Brookfield Business Partners L.P. What are the tax consequences of this exchange?
A U.S. shareholder's exchange of class A shares for units generally is expected to be treated for U.S. federal income tax purposes as a taxable sale or exchange, based on how we expect to satisfy our obligations under the exchange rights. This assumes, among other things, that the exchanging shareholder experiences a reduction in his or her equity interest in Brookfield Business Corporation as a result of the exchange (taking into account any "constructively" owned equity interests). The taxable gain or loss recognized generally is expected to equal the difference between the value of the Brookfield Business Partners LP units and any cash received (at the time of the exchange) and the shareholder's adjusted tax basis in the Brookfield Business Corporation class A shares exchanged.
These questions and answers are for general information purposes only and are not legal or tax advice. Brookfield does not provide legal or tax advice. Please consult your own tax adviser regarding your personal tax circumstances.
I am a European resident. Is the dividend I am paid from Brookfield Business Corporation subject to withholding tax?
Dividends paid from Brookfield Business Corporation to European resident shareholders may be subject to Canadian withholding tax. The rate of withholding varies, amongst other factors, depending on the type of ownership account, the tax residency of the shareholder, and whether shareholders have provided their broker (or Brookfield Business Corporation’s transfer agent in the case of registered shareholders) with the appropriate Canada Revenue Agency (“CRA”) form (Form NR301, NR302, and NR303).
These questions and answers are for general information purposes only and are not legal or tax advice. Brookfield does not provide legal or tax advice. Please consult your own tax adviser regarding your personal tax circumstances.
What is the tax nature of the distributions paid by Brookfield Business Corporation?
Distributions from Brookfield Business Corporation are expected to be unfranked dividends to Australian tax resident unitholders.
I am an Australian resident. Is the dividend I am paid from Brookfield Business Corporation subject to withholding tax?
Dividends paid from Brookfield Business Corporation to an Australian resident shareholder may be subject to Canadian withholding tax. The rate of withholding varies, amongst other factors, depending on the type of ownership account, and whether shareholders have provided their broker (or Brookfield Business Corporation’s transfer agent in the case of registered shareholders) with the appropriate Canada Revenue Agency (“CRA”) form (Form NR301, NR302, and NR303). The withholding tax rate can range from nil to 25%.
These questions and answers are for general information purposes only and are not legal or tax advice. Brookfield does not provide legal or tax advice. Please consult your own tax adviser regarding your personal tax circumstances.
CONTACT INFORMATION
Investor Enquiries
For investor-related information, please email: [email protected]
or call our investor line:
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Global: +1-416-363-9491
Investor Relations Contact
Alan Fleming
Managing Director, Investor Relations
Tel: +1-416-645-2736
Email: [email protected]
Transfer Agent
TSX Trust Company
P.O Box 700, Station B
Montreal, QC H3B 3K3
Canada
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(in the U.S. and Canada)
Tel: +1-416-682-3860
Fax: 1-888-249-6189
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www.amstock.com
Shareholder Services
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