Tax Information

Nature of Brookfield Dividends
Brookfield is a “qualified foreign corporation” for U.S. federal income tax purposes and its dividends are therefore generally eligible for “qualified dividend” treatment. Whether dividends paid by Brookfield will in fact be “qualified dividends” to any shareholder will depend on that shareholder’s specific circumstances, including the shareholder’s holding period for the Brookfield shares on which such dividends are received. U.S. shareholders are advised to consult their own tax advisors concerning the treatment of dividends paid by Brookfield.

Based on the current and anticipated composition of the income, assets and operations of Brookfield and its subsidiaries, Brookfield does not believe that it will be a Passive Foreign Investment Company (“PFIC”) for U.S. federal income tax purposes for the current taxable year or for the foreseeable future. However, the application of the PFIC rules is subject to uncertainty in several respects, and a separate determination must be made after the close of each taxable year as to whether Brookfield is a PFIC for that year. Changes in the composition of Brookfield’s income or assets may cause Brookfield to become a PFIC. Accordingly, there can be no assurance that Brookfield will not be a PFIC for any taxable year.

Tax Reporting
Dividends paid by Brookfield are reported annually on Form 1099 which is distributed to shareholders in February.

Withholding Tax on Dividends
Under Canadian domestic law, dividends paid by Brookfield to a non-Canadian tax resident shareholder are subject to 25% withholding tax. Generally, the Canada – U.S. Income Tax Treaty will reduce the rate of dividend withholding tax from 25% down to 15% for a resident of the United States. Where the U.S. resident owns the shares of Brookfield in a 401K, IRA or similar plan, the Canada – U.S. Income Tax Treaty will generally reduce the rate of dividend withholding tax to nil.

Nature of Brookfield Dividends
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 to Canadian tax residents on Brookfield’s shares are designated as “eligible dividends.” Unless stated otherwise, all dividends (and deemed dividends) are designated as “eligible dividends” for the purposes of these rules.

Tax Reporting
Dividends paid by Brookfield are reported annually on Form T5 which is distributed to shareholders in February.

Brookfield’s U.K. Tax Strategy

Brookfield Asset Management Ltd.’s (“Brookfield” or the “Company”) U.K. tax strategy is consistent with the Company’s overall global tax strategy and covers all U.K. entities consolidated in Brookfield’s financial statements which are prepared in conformity with accounting principles generally accepted in the United States of America. Brookfield regards the publication of the information set out below as compliance with the duty under Finance Act 2016, Schedule 19, paragraph 16 to publish a tax strategy and applies for accounting periods ending within the 2024 calendar year.

Brookfield is committed to full compliance with all statutory obligations and full disclosure to tax authorities. The Company’s tax affairs are managed in a way which considers the corporate reputation and are done in line with Brookfield’s overall high standards of governance.

Risk Management and Governance

Brookfield’s Risk Management Committee (“RMC”), which is comprised of members of Brookfield’s Board of Directors, has oversight for risk management of the Brookfield group, including those risks related to taxation. The RMC has approved Brookfield’s Tax Risk Management Policy (the “Policy”) and reviews material tax risks quarterly. The RMC reports relevant tax matters to the Board of Directors if appropriate. Consistent with how all risks are managed, tax risks are managed on a decentralized basis and the senior management of each business unit is responsible for adhering to the Policy. The Chief Financial Officer and Managing Partner of Tax of the Company are responsible for taxation have oversight of tax risks across the organization and are authorized to manage the tax risks and approve tax positions, tax settlements and payments, in accordance with the Policy.

Tax Planning

Brookfield seeks to comply with tax laws and filing deadlines in the jurisdictions in which Brookfield operates having regard to the legal and administrative practices in each jurisdiction. Brookfield may utilize available tax incentives, reliefs and exemptions provided these are aligned with the associated tax legislation.

Managing Tax Risk

Brookfield actively seeks to identify, evaluate, monitor, and manage tax risks to ensure that they are consistent with Brookfield’s objectives. In reviewing the tax risks associated with the business operations, Brookfield will consider the following:

• legal duties of directors and employees;
• compliance with internal policies and procedures;
• impact on Brookfield’s relationships with tax authorities; and
• maintenance of Brookfield’s reputation as a world class asset manager.

In situations where tax law is unclear or subject to interpretation or Brookfield does not have the internal expertise to assess a particular tax position, tax advice is obtained from external advisors who have the appropriate technical expertise.

Relationship with HM Revenue & Customs

Brookfield is committed to maintaining a cooperative and open working relationship with HM Revenue & Customs (“HMRC”) and ensuring that any tax audits are efficiently and effectively managed. Brookfield seeks to make fair, accurate and timely disclosures in correspondence and tax returns and respond to queries in a timely manner.

December 2024