Trisura Group Spin-off

Dividend Details
On June 22, 2017, Brookfield Asset Management Inc. (“Brookfield”) made a special dividend payment to holders of its Class A Limited Voting Shares (“Class A Shares”) and Class B Limited Voting Shares (“Class B Shares”) of one common share of Trisura Group Ltd. (“Trisura”) for every 170 Class A Shares and Class B Shares held as of the close of business of June 1, 2017, the record date for the special dividend.

Immediately following payment of the dividend, shareholders of Brookfield owned 100% of Trisura, with Brookfield retaining no interest in the company.  There is approximately 5.8 million Trisura common shares outstanding now following payment of the special dividend.

About Trisura
Trisura is a leading international specialty insurance provider operating in the surety, risk solutions, corporate insurance and reinsurance segments of the market. Trisura has three principal regulated subsidiaries: Trisura Guarantee Insurance Company, Trisura International Insurance and Trisura Specialty Insurance Company. Trisura is listed on the Toronto Stock Exchange under the symbol "TSU".

Tax Considerations
For Canadian Holders

June 2017 Special Dividend
On June 22, 2017, Brookfield Asset Management Inc. (BAM) paid a special in-kind dividend of common shares of Trisura Group Ltd. (TSU) to its shareholders.

The amount of the taxable eligible dividend for Canadian recipients is equal to the fair market value of the common shares (including any fractional common shares that were paid in cash) that were received on that date which is CAD $0.1254 for every BAM shares.

The CAD $0.1254 amount was determined by multiplying (i) the weighted average trading price of the TSU common shares on the Toronto Stock Exchange for the five trading days commencing on June 22, 2017 (a commonly used method) of CAD $21.3170 per common share by (ii) the number of TSU common shares received for each BAM shares, or one TSU common share for every 170 common shared held of BAM (approximately 0.00588).

For U.S. Holders

June 2017 Special Dividend
On June 22, 2017, Brookfield Asset Management Inc. (BAM) made a special in-kind distribution of common shares of Trisura Group Ltd. (TSU) to its shareholders.

Please refer to the IRS Form 8937 for details on the U.S. tax treatment of the special distribution.

For U.S. federal income tax purposes, Trisura and Brookfield intend to treat the special distribution of common shares of Trisura as a tax-free distribution under Section 355 of the Internal Revenue Code.  Assuming that the distribution qualifies as tax-free, the distribution of common shares of Trisura to U.S. holders of Class A Shares will result in the following tax consequences:

  • A U.S. holder will not recognize any income, gain or loss as a result of the receipt of Trisura common shares received in the distribution (except for any cash received in lieu of fractional common shares).
  • The receipt of cash in lieu of fractional common shares of Trisura generally will be treated as a sale of the fractional common shares, and a U.S. holder will recognize a gain or loss equal to the difference between the amount of cash received and such holder’s basis in the fractional common shares, as determined above.
  • The aggregate tax basis in Class A Shares and Trisura common shares in the hands of each U.S. holder immediately after payment of the special distribution will be the same as the aggregate tax basis of the Class A Shares held by such holder immediately prior to payment of the special distribution, allocated between the Class A Shares and Trisura common shares (including fractional common shares) in proportion to their relative fair market values immediately following payment of the special distribution.

June 1, 2017
BAM Letter to Shareholders - Trisura Group (English)
BAM Letter to Shareholders - Trisura Group (French)

For further information regarding the special dividend of common shares of Trisura please refer to the Prospectus and U.S. Information Statement dated May 12, 2017.