Is Brookfield Infrastructure Partners a Limited Partnership, Corporation or Trust?
Brookfield Infrastructure Partners L.P. (Brookfield Infrastructure Partners) is a Bermuda based limited partnership that is treated as a partnership for Canadian tax purposes. Brookfield Infrastructure Partners is not a corporation or a trust.

What is the tax nature of the income earned by Brookfield Infrastructure Partners?

Brookfield Infrastructure Partners is a publicly traded partnership that does not earn active business income. Instead, Brookfield Infrastructure Partners receives various types of investment income, such as interest, dividends and return of capital, from subsidiary corporations that carry on business in various jurisdictions.

The amount of interest, dividends and returns of capital that is earned and then allocated to unitholders will vary depending upon the particular business unit(s) from which funds are sourced. The source of funds for the distributions will also affect how much, if any, of the distributions are subject to withholding tax.

Is Brookfield Infrastructure Partners eligible for Tax-Deferred Plans?

In Canada, Brookfield Infrastructure Partners 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 Unitholder?

After the end of Brookfield Infrastructure Partners' taxation year (December 31), the Canadian taxable income of Brookfield Infrastructure Partners is determined and allocated to all unitholders that are in turn required to report such income on their respective tax returns. The allocation of Canadian taxable income is communicated using Form T5013 (not a Form T5).

In general, the distributions you receive should equal the sum of (i) the net of all income and expenses and (ii) return of capital, reported on Form T5013. There may be minor differences due to exchange rates.

Additionally, Brookfield Infrastructure Partners is required to use reasonable efforts to send a Schedule K-1 to all unitholders, including those who may not require it. The Schedule K-1 is the U.S. equivalent of a Form T5013. Receipt of a Schedule K-1 does not trigger a U.S. tax return filing obligation or indicate that one is required.

Who will send my Tax Form (T5013)?

Beneficial Canadian unitholders (i.e., those holding their units in street name with their brokerage) should receive a T5013 from their Canadian broker. If you are a beneficial Canadian resident unitholder and did not receive your Form T5013, please contact the brokerage firm with whom your units are held.

RegisteredCanadian unitholders will receive a T5013 directly from Brookfield Infrastructure Partners. If you are a registeredCanadian resident holder and did not receive your Form T5013 for the previous taxation year please contact (866) 949-2771 or at
www.taxpackagesupport.com/brookfield.

When will I (non-registered unitholder) receive my Tax Form (T5013)?
Brookfield Infrastructure Partners uses the CDS Innovations facility to provide information to Canadian brokers on or before the end of February following the end of each taxation year so that they can produce T5013 Forms. The statutory filing/mailing requirement for Form T5013 is the end of March. Typically, brokers will prepare and distribute the Form T5013 in late March. If you have any questions about Form T5013 you should contact your broker.

I am a beneficial unitholder and haven’t received my T5013. Can you send a replacement form?
We cannot send a replacement form to a non-registered unitholder. Generally, T5013 forms are prepared and distributed by brokers based on information we provide on or before the end of February following the end of each taxation year to CDS Innovations which is typical for publicly traded securities. The statutory filing/mailing requirement for Form T5013 is the end of March. Typically, brokers will prepare and distribute the Form T5013 in late March.

Why does the $CAD cash I received not equal the amount reflected on my T5013?
In general, the distributions you receive should equal the sum of (i) the net of all income and expenses and (ii) return of capital, reported on Form T5013. There may be minor differences due to exchange rates. If you have elected to receive distribution in CAD, there will be a record date and a payment date. There could be a discrepancy in the FX rate used between the record and payment dates.

Why did I receive a Schedule K-1?
Brookfield Infrastructure Partners is required to use reasonable efforts to send a Schedule K-1 to all unitholders, including those who may not require it. The Schedule K-1 is the U.S. equivalent of a Form T5013. Receipt of a Schedule K-1 does not trigger a U.S. tax return filing obligation or indicate that one is required. Owning a unit of BIP LP does not provide you with a U.S. tax filing obligation. If you are not already required to file a U.S. tax return, the Schedule K-1 is not required and it can be discarded.

I am a Canadian resident. Is the distribution I am paid from Brookfield Infrastructure Partners subject to Withholding Tax?
Brookfield Infrastructure Partners is a “flow through” entity for Canadian income tax purposes, and its income comes from holding companies the partnership owns. At present, these holdings companies are in Canada, US, or Bermuda, and we do not expect this to change for the foreseeable future. Payments from holding companies in Canada and Bermuda to a Canadian resident are not subject to withholding tax. Payments from holding companies in the US to a Canadian resident such as dividends may be subject to withholding taxes. The rate of withholding varies, amongst other factors, depending on the type of ownership account, and whether holders have provided their broker (or Brookfield Infrastructure Partners L.P.’s transfer agent in the case of registered unitholders) with the appropriate Internal Revenue Service (“IRS”) Form (Form W-8BEN, W-8BEN-E, W-8-ECI, W-8EXP, W-8IMY or W-9). Note that as Brookfield Infrastructure Partners has not and is not expected to generate effectively connected income (ECI), we do not expect non-U.S. investors to be subject to U.S. tax withholding under IRC Section 1446(b) and 1446(f)

Withholding tax information for quarterly distributions will be posted approximately two weeks prior to each distribution payment date on the tax section of our website.

What is Brookfield Infrastructure Partners’ Partnership ID Number?
Brookfield Infrastructure Partners’ Canadian tax identification number (Business Number) is 83812 9450 RZ0001.

What does box 135 signify?
Box 135 shows the country code for source of foreign income. BMU identifies the source of the income as Bermuda. USA identifies the source of the income as United States.

Can I E-File my tax return?
Yes, the T5013 Form you receive should include all information that is required by law for you to e-file your Canadian personal tax return. Please note that one’s personal tax circumstances must be taken into account and that the CRA will, in certain circumstances, require individuals to submit their tax returns in a paper format.

My tax software requires that I insert a North American Industry Classification System (NAICS) code. What is Brookfield’s NAICS?
The T5013 form does not require us to report a NAICS code but it would seem some personal software tax programs ask for them. Please select the NAICS code you deem most appropriate. The NAICS codes should have no impact on the computation of your taxes.

My tax software requires that I insert a six-digit Tax Shelter (TS) number. What is Brookfield Infrastructure Partners’ TS number?
Brookfield Infrastructure Partners is not a tax shelter and therefore does not have an applicable TS number. If your tax software requires this number to proceed with your filing, please contact customer support for the tax preparation software that you are using and they may be able to assist you.

Is Brookfield Infrastructure Partners a Specified Foreign Property?
For the purpose of reporting foreign property by Canadian investors, pursuant to section 233.3 of the Canadian Income Tax Act, Brookfield Infrastructure Partners is not a specified foreign property and therefore does not need to be reported on Form T1135 Foreign Income Verification Statement.

What is Brookfield Infrastructure Partners’ Quebec Tax ID Number?
Brookfield Infrastructure Partners does not have a Quebec number because it is non-resident of Quebec.

Are units considered foreign property for the purposes of the Canada Revenue Agency T-1135 Form – Foreign Income Verification Statement?
No.

How can I obtain a tax credit for foreign taxes withheld?
Box 171 on the T5013 tax slip should show the foreign taxes withheld. Alternatively, Canadian unitholders can find information about the amount of taxes withheld on their monthly/annual broker statements.

What is my Adjusted Cost Base?
For Canadian residents, in general, a unitholder's tax cost of his/her Brookfield Infrastructure Partners units should equal the sum of (i) the amount paid to acquire the units and (ii) the net of all income and expenses reported on Form T5013, minus the cash distributions received.

For Canadian residents, the tax cost of units is determined in Canadian dollars so all three components should be determined in Canadian dollars. Brookfield Infrastructure Partners L.P. does not have sufficient information to track the tax cost of units for each individual holder. Depending upon the particular taxation year, the T5013 will report various sources of income and expenses in a number of boxes on the form. The net taxable income allocated is the sum of the various income and expenses. Unitholders are obligated to accurately compute the tax cost of their Brookfield Infrastructure Partners L.P. units.

Does Brookfield Infrastructure Partners generate any Unrelated Business Taxable Income (UBTI)?
Brookfield Infrastructure Partners is not anticipated to generate UBTI and has not generated any in prior years.

Has Brookfield Infrastructure Partners generated or is it expected to generate Effectively Connected Income (ECI) or Commercial Activity income?
No, Brookfield Infrastructure Partners has not and is not expected to generate effectively connected income (ECI) or commercial activity income (on a global basis). Furthermore, Brookfield Infrastructure Partners does not directly own any assets used in a U.S. trade or business. Brookfield Infrastructure Partners’ U.S. operations are carried out through U.S. resident corporate subsidiaries.

Am I subject to Foreign Investment Real Property Tax Act (FIRPTA)?
Non-U.S. investors that own 5% or less of Brookfield Infrastructure Partners publicly traded units should not be subject to FIRPTA taxation on a disposition of their units. Investors that own more than 5% of Brookfield Infrastructure Partners publicly traded units may be subject to FIRPTA taxation on a disposition of their units.

Am I subject to U.S. tax withholding under IRC Section 1446(f) on the disposition of Brookfield Infrastructure Partner units?
We do not expect non-U.S. investors to be subject to U.S. tax withholding under IRC Section 1446(f) on the disposition of their units. Brookfield Infrastructure Partners has not been and does not expect to be engaged in a U.S. trade or business within the meaning of Treas. Reg. Sec. 1.1446(f)-4(b)(3)(ii)(A)(2). Brookfield Infrastructure Partners has issued qualified notices in accordance with Treas. Reg. Sec. 1.1446(f)-4(b)(3)(iii) as applicable. Previously issued notices can be found in the “Qualified Notices” section below. Please also see a letter from counsel on this issue, as well as more detailed discussion on this new rule and its applicability to BIP units.

I owned units of Brookfield Infrastructure Partners L.P. prior to the formation of Brookfield Infrastructure Corporation. As a result of the special distribution from Brookfield Infrastructure Partners L.P. in 2020, I received class A shares of Brookfield Infrastructure 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 Infrastructure 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 Infrastructure 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 base. The 5-day volume weighted average price (VWAP) ending April 6, 2020 of a share of Brookfield Infrastructure Corporation on the Toronto Stock Exchange was $50.12. On Jun 13, 2022, there was a 3 for 2 share split in the shares of Brookfield Infrastructure Corporation. Please consult with your tax advisor on how the share split would impact your adjusted cost base of your Brookfield Infrastructure Corporation shares.

Is Brookfield Infrastructure Partners a Limited Partnership, Corporation or Trust?
Brookfield Infrastructure Partners is a Bermuda based limited partnership that is treated as a partnership for U.S. tax purposes. Brookfield Infrastructure Partners is not a corporation or a trust.

What is the tax nature of the income earned by Brookfield Infrastructure Partners?
Brookfield Infrastructure Partners is a publicly traded partnership that does not earn active business income. Instead, Brookfield Infrastructure Partners receives various types of passive investment income, such as interest, dividends and return of capital, from subsidiary corporations that carry on business in various jurisdictions.

The amount of interest, dividends and returns of capital that is earned and then allocated to unitholders will vary depending upon the particular business unit(s) from which funds are sourced. The source of funds for the distributions will also affect how much if any of the distributions are subject to withholding tax.

A significant portion of Brookfield Infrastructure Partner’s income is Bermuda source dividend which is a fully taxable "ordinary dividend’. Dividends from Canada and US are "qualified dividends" and therefore eligible for a preferential U.S. income tax rate (for individuals)¹.

What is Brookfield Infrastructure Partners’ Partnership ID Number?
Brookfield Infrastructure Partners’ U.S. tax identification number (Employer Identification Number) is 98-0330282.

Is Brookfield Infrastructure Partners eligible for Tax-Deferred Plans?
In the U.S., units of Brookfield Infrastructure Partners qualify for IRA and 401(k) accounts.

What Tax Form will I receive as a U.S. Unitholder?
After the end of Brookfield Infrastructure Partners' taxation year (December 31), the U.S. taxable income of Brookfield Infrastructure Partners is determined and allocated to all unitholders that are in turn required to report such income on their respective tax returns. The allocation of U.S. taxable income is communicated using Schedule K-1.

Who will send my Tax Form and when will I receive it (K-1)?
We are required to use reasonable efforts to send a Schedule K-1 to all unitholders. We expect to provide Schedule K-1 tax information via our online portal by mid-February and to have those forms mailed to our U.S. unitholders by the end of March.

If you are a U.S. unitholder and did not receive your Schedule K-1 for the previous taxation year please contact us at (866) 949-2771 or at www.taxpackagesupport.com/brookfield. Alternatively, use the link to Tax Package Support at the right side of this page.

If you believe you have received a Schedule K-1 in error, wish to correct the K-1 you have been issued, or have any other questions related to your K-1, please contact Tax Package Support at (866) 949-2771. Please note that we are required to issue K-1 forms to all U.S. unitholders, regardless if their units are held in a tax deferred account such as an IRA. If your units are held in an IRA, you generally do not need to report the amounts on your K-1 and you should keep your K-1 for your records.

Why haven’t I received a K-1?
Generally, our unitholders own their units in "nominee form" through brokerages and we rely on information acquired from brokers and/or clearing houses to prepare the Schedule K-1. We are not always able to acquire information for all unitholders and accordingly some unitholders may not receive a Schedule K-1 for a particular year despite our best efforts to do so. If you do not receive a K-1 and require one, please contact Tax Package Support at (866) 949-2771 or www.taxpackagesupport.com/brookfield and they will assist you.

I believe my K-1 is incorrect – who should I contact to fix this?
We rely on information provided by brokers and/or clearing houses to prepare Schedule K-1. In limited cases the information provided to us may be incomplete and/or inaccurate. In the event you believe your K-1 is incorrect please contact Tax Package Support at (866) 949 2771 or www.taxpackagesupport.com/brookfield and an amended Form K1 will be issued.

How can I obtain a tax credit for foreign taxes withheld?
The Forms 1099-INT and DIV prepared by your broker will include information on any foreign withholding taxes that were withheld by your broker so that you may claim them, if eligible, in your tax return as a credit and/or deduction. Because the withholding tax process is administered by the brokerage community rather than us, taxes withheld are only reported on Forms 1099-INT and 1099-DIV (and not on Schedule K-1).

Can I E-File my tax return?
Yes, the K-1 Form you receive should include all information that is required by law for you to e-file your U.S. personal tax return. Please note that one’s personal tax circumstances must be taken into account and that the IRS will, in certain circumstances, require individuals to submit their tax returns in a paper format.

I am a U.S. resident. Is the distribution I am paid from Brookfield Infrastructure Partners subject to Withholding Tax?
Brookfield Infrastructure Partners is a "flow through" entity for US income tax purposes, and its income comes from holding companies the partnership owns. At present, these holdings companies are in Canada, US, or Bermuda, and we do not expect this to change for the foreseeable future. Payments from holding companies in US and Bermuda to a US resident are generally not subject to withholding tax. Payments from holding companies in Canada to a US resident such as dividends may be subject to withholding taxes. The rate of withholding varies, amongst other factors, depending on the type of ownership account, and whether holders have provided their broker (or Brookfield Infrastructure Partners L.P.’s transfer agent in the case of registered unitholders) with the appropriate Canada Revenue Agency ("CRA") form (Form NR301, NR302, and NR303).

What is my Adjusted Cost Basis?
For U.S. residents, in general, a unitholder's tax cost of his/her Brookfield Infrastructure Partners units should equal the sum of (i) the amount paid to acquire the units and (ii) the net taxable income allocated to the unitholder, minus the cash distributions received.

Brookfield Infrastructure Partners does not have sufficient information to track the tax cost of units for each individual holder. Unitholders are solely responsible to accurately compute and track the tax cost of their Brookfield Infrastructure Partners units.

Is Brookfield Infrastructure Partners considered Passive Foreign Investment Company (PFIC) or Controlled Foreign Corporation (CFC)?
Brookfield Infrastructure Partners is not considered a PFIC or CFC for U.S. tax purposes.

Does Brookfield Infrastructure Partners generate UBTI?
Brookfield Infrastructure Partners is not anticipated to generate UBTI and has not generated any in prior years.

I owned units of Brookfield Infrastructure Partners L.P. prior to the formation of Brookfield Infrastructure Corporation. As a result of the special distribution from Brookfield Infrastructure Partners L.P. in 2020, I received class A shares of Brookfield Infrastructure Corporation. Is this special distribution taxable for U.S. federal income tax purposes?
Brookfield Infrastructure Partners L.P. is expected to qualify as an "investment" partnership" so that the special distribution of class A shares of Brookfield Infrastructure Corporation to a U.S. unitholder who is an "eligible partner" qualifies as a non-taxable distribution of property. The initial basis tax basis in the class A shares received in the special distribution by a U.S. unitholder that qualifies as an eligible partner will equal the lesser of (i) Brookfield Infrastructure Partners L.P.'s adjusted tax basis in such class A shares immediately before the distribution of $35.748 per share and (ii) such U.S. unitholder's adjusted tax basis in its interest in Brookfield Infrastructure Partners L.P. reduced by the amount of any cash received in lieu of fractional class A shares pursuant to the special distribution. On Jun 13, 2022, there was a 3 for 2 share split in the shares of Brookfield Infrastructure Corporation. Please consult with your tax advisor on how the share split would impact your adjusted cost basis of your Brookfield Infrastructure Corporation shares.

¹We report the gross distribution and the portion of the distribution that is eligible to be treated as a “qualified dividend” for U.S. tax purposes on our Schedule K-1 that is issued to U.S. unitholders in February of the following year. These amounts will vary from year-to-year and are calculated in accordance with U.S. tax rules.

Is Brookfield Infrastructure Partners a Limited Partnership, Corporation or Trust?
Brookfield Infrastructure Partners L.P. (Brookfield Infrastructure Partners) is a Bermuda based limited partnership that is treated as a partnership for Canadian tax purposes. Brookfield Infrastructure Partners is not a corporation or a trust.

Is Brookfield Infrastructure Partners a Limited Partnership, Corporation or Trust?
Brookfield Infrastructure Partners is a Bermuda based limited partnership. Brookfield Infrastructure Partners is not a corporation or a trust.

Does Brookfield Infrastructure Partners generate any Unrelated Business Taxable Income (UBTI)?
Brookfield Infrastructure Partners is not anticipated to generate UBTI and has not generated any in prior years.

Has Brookfield Infrastructure Partners generated or is it expected to generate Effectively Connected Income (ECI) or Commercial Activity income?
No, Brookfield Infrastructure Partners has not and is not expected to generate effectively connected income (ECI) or commercial activity income (on a global basis). Furthermore, Brookfield Infrastructure Partners does not directly own any assets used in a U.S. trade or business. Brookfield Infrastructure Partners’ U.S. operations are carried out through U.S. resident corporate subsidiaries.

Am I subject to Foreign Investment Real Property Tax Act (FIRPTA)?
Non-U.S. investors that own 5% or less of Brookfield Infrastructure Partners publicly traded units should not be subject to FIRPTA taxation on a disposition of their units. Investors that own more than 5% of Brookfield Infrastructure Partners publicly traded units may be subject to FIRPTA taxation on a disposition of their units.

Am I subject to U.S. tax withholding under IRC Section 1446(f) on the disposition of Brookfield Infrastructure Partner units?
We do not expect non-U.S. investors to be subject to U.S. tax withholding under IRC Section 1446(f) on the disposition of their units. Brookfield Infrastructure Partners has not been and does not expect to be engaged in a U.S. trade or business within the meaning of Treas. Reg. Sec. 1.1446(f)-4(b)(3)(ii)(A)(2). Brookfield Infrastructure Partners has issued qualified notices in accordance with Treas. Reg. Sec. 1.1446(f)-4(b)(3)(iii) as applicable. Previously issued notices can be found in the “Qualified Notices” section below. Please also see a letter from counsel on this issue below, as well as more detailed discussion on this new rule and its applicability to BIP units.

Why did I receive a Schedule K-1?
Brookfield Infrastructure Partners is required to use reasonable efforts to send a Schedule K-1 to all unitholders, including those who may not require it. Receipt of a Schedule K-1 does not trigger a U.S. tax return filing obligation or indicate that one is required. Owning a unit of BIP LP does not provide you with a U.S. tax filing obligation. If you are not already required to file a U.S. tax return, the Schedule K-1 is not required and it can be discarded.

I am a European resident. Is the distribution I am paid from Brookfield Infrastructure Partners subject to Withholding Tax?
While Brookfield Infrastructure Partners is a Bermuda partnership, its income comes from holding companies the partnership owns. At present, these holdings companies are either in Canada, US or Bermuda, and we do not expect this to change for the foreseeable future. The income Brookfield Infrastructure Partners earns from underlying subsidiaries includes dividends and interest paid by subsidiaries in jurisdictions that levy withholding tax. Since Brookfield Infrastructure Partners is a "flow-through" for U.S. and Canadian income tax purposes, a portion of the income may be subject to withholding taxes levied by jurisdictions such as the U.S. and Canada. Note that as Brookfield Infrastructure Partners has not and is not expected to generate effectively connected income (ECI), we do not expect non-U.S. investors to be subject to U.S. tax withholding under IRC Section 1446(b) and 1446(f)

The rate of withholding varies, amongst other factors, depending on a holder’s country of tax residence, type of ownership account, and whether holders have provided their broker (or Brookfield Infrastructure Partners’ transfer agent in the case of registered unitholders) with the appropriate Internal Revenue Service ("IRS") Form (Form W-8BEN, W-8BEN-E, W-8-ECI, W-8EXP, W-8IMY or W-9) and Canada Revenue Agency ("CRA") Form (Form NR301, NR302, and NR303).

Who applies the withholding tax? Why don’t I receive the full distribution amount?
Generally, our unitholders own their units in "nominee form" through brokers (also known as "beneficial" holders). Consequently, the brokers are responsible for withholding taxes as only they possess the requisite information about the unitholder that is necessary to calculate the appropriate amount to withhold as is typical for publicly traded securities. Historically, our partnership’s income has included Canadian and US source interest and dividends earned from subsidiaries that, when paid to a European unitholder, are subject to varying rates of U.S. and Canadian withholding taxes ranging from nil to 30%.

Is Brookfield Infrastructure Partners a Limited Partnership, Corporation or Trust?
Brookfield Infrastructure Partners L.P. (Brookfield Infrastructure Partners) is a Bermuda based limited partnership that is treated as a partnership for Canadian tax purposes. Brookfield Infrastructure Partners is not a corporation or a trust.

Is Brookfield Infrastructure Partners a Limited Partnership, Corporation or Trust?
Brookfield Infrastructure Partners L.P. is characterized as a corporate limited partnership for Australian income tax purposes. This broadly means Brookfield Infrastructure Partners L.P. is treated as a company for Australian income tax purposes.

What is the tax nature of the income earned by Brookfield Infrastructure Partners?
For Australian income tax purposes, Brookfield Infrastructure Partners L.P. is treated as a corporation (i.e, not a "flow-through") and consequently distributions are expected to be unfranked dividends to Australian tax resident unitholders.

What Tax Form will I receive as an Australian Unitholder?
Brookfield Infrastructure Partners L.P. will not be issuing any Australian tax forms. We would generally expect Australian tax resident unitholders to treat Brookfield Infrastructure Partners L.P.'s distributions as unfranked dividends unless otherwise advised.

Additionally, Brookfield Infrastructure Partners is required to use reasonable efforts to send a Schedule K-1 to all unitholders, including those who may not require it. The Schedule K-1 is the U.S. equivalent of a Form T5013. Receipt of a Schedule K-1 does not trigger a U.S. tax return filing obligation or indicate that one is required.

Why did I receive a Schedule K-1?
Brookfield Infrastructure Partners is required to use reasonable efforts to send a Schedule K-1 to all unitholders, including those who may not require it. Receipt of a Schedule K-1 does not trigger a U.S. tax return filing obligation or indicate that one is required. Owning a unit of BIP LP does not provide you with a U.S. tax filing obligation. If you are not already required to file a U.S. tax return, the Schedule K-1 is not required and it can be discarded.

Does Brookfield Infrastructure Partners generate any Unrelated Business Taxable Income (UBTI)?
Brookfield Infrastructure Partners is not anticipated to generate UBTI and has not generated any in prior years.

Has Brookfield Infrastructure Partners generated or is it expected to generate Effectively Connected Income (ECI) or Commercial Activity income?
No, Brookfield Infrastructure Partners has not and is not expected to generate effectively connected income (ECI) or commercial activity income (on a global basis). Furthermore, Brookfield Infrastructure Partners does not directly own any assets used in a U.S. trade or business. Brookfield Infrastructure Partners’ U.S. operations are carried out through U.S. resident corporate subsidiaries.

Am I subject to Foreign Investment Real Property Tax Act (FIRPTA)?
Non-U.S. investors that own 5% or less of Brookfield Infrastructure Partners publicly traded units should not be subject to FIRPTA taxation on a disposition of their units. Investors that own more than 5% of Brookfield Infrastructure Partners publicly traded units may be subject to FIRPTA taxation on a disposition of their units.

Am I subject to U.S. tax withholding under IRC Section 1446(f) on the disposition of Brookfield Infrastructure Partner units?
We do not expect non-U.S. investors to be subject to U.S. tax withholding under IRC Section 1446(f) on the disposition of their units. Brookfield Infrastructure Partners has not been and does not expect to be engaged in a U.S. trade or business within the meaning of Treas. Reg. Sec. 1.1446(f)-4(b)(3)(ii)(A)(2). Brookfield Infrastructure Partners has issued qualified notices in accordance with Treas. Reg. Sec. 1.1446(f)-4(b)(3)(iii) as applicable. Previously issued notices can be found in the “Qualified Notices” section below. Please also see a letter from counsel on this issue, as well as more detailed discussion on this new rule and its applicability to BIP units.

I am an Australian resident. Is the distribution I am paid from Brookfield Infrastructure Partners subject to Withholding Tax?
While Brookfield Infrastructure Partners is a Bermuda partnership, its income comes from holding companies the partnership owns. At present, these holdings companies are either in Canada, US or Bermuda, and we do not expect this to change for the foreseeable future. The income Brookfield Infrastructure Partners earns from underlying subsidiaries includes dividends and interest paid by subsidiaries in jurisdictions that levy withholding tax. Since Brookfield Infrastructure Partners is a "flow-through" for U.S. and Canadian income tax purposes, a portion of the income may be subject to withholding taxes levied by jurisdictions such as the U.S. and Canada. Note that as Brookfield Infrastructure Partners has not and is not expected to generate effectively connected income (ECI), we do not expect non-U.S. investors to be subject to U.S. tax withholding under IRC Section 1446(b) and 1446(f)

The rate of withholding varies, amongst other factors, depending on a holder’s country of tax residence, type of ownership account, and whether holders have provided their broker (or Brookfield Infrastructure Partners’ transfer agent in the case of registered unitholders) with the appropriate Internal Revenue Service (IRS) Form (Form W-8BEN, W-8BEN-E, W-8-ECI, W-8EXP, W-8IMY or W-9) and Canada Revenue Agency (CRA) Form (Form NR301, NR302, and NR303).

Who applies the withholding tax? Why don’t I receive the full distribution amount?
Generally, our unitholders own their units in nominee form through brokers (also known as beneficial holders). Consequently, the brokers are responsible for withholding taxes as only they possess the requisite information about the unitholder that is necessary to calculate the appropriate amount to withhold as is typical for publicly traded securities. Historically, our partnership’s income has included Canadian and US source interest and dividends earned from subsidiaries that, when paid to an Australian unitholder, are subject to varying rates of U.S. and Canadian withholding taxes ranging from nil to 30%.

What is the tax cost of my units?
For Australian residents, the tax cost of units is the amount paid for Brookfield Infrastructure Partners L.P. units plus any incidental costs incurred to acquire them. As Brookfield Infrastructure Partners L.P. is treated as a corporation its distributions will be fully taxable and do not affect the tax cost of a Brookfield Infrastructure Partners L.P. unit.