Tem a ver com a estrutura dos títulos (acções vs. income trusts) e a sua fiscalidade (Canada vs. Bermuda), o mesmo acontece com outras entidades do grupo da Brookfield, BIPC/BIP:
When Brookfield Renewable listed as a C-Corp under the BEPC ticker, BEPC initially clearly outperformed BEP despite both companies being economically equivalent. The only difference is that BEP is a publicly traded partnership sitting in Bermuda whereas BEPC is a Canadian corporation listed on NYSE and TSX as a means to “provide investors with greater flexibility in how they access BEP’s globally diversified portfolio of high-quality renewable power assets” .
BIP.UN and BIPC will pay the same US dollar distribution paid quarterly. As such the stock prices will also trade closely within a range. The only difference between the two comes down to taxation. Given that BIP.UN is a Bermuda-based limited partnership, distributions historically included foreign dividend and interest income, Canadian source interest, other investment income and capital gains, as well as return of capital. Return of capital is not immediately taxable but is effectively a capital gains tax when the units are sold. The BIPC dividend would be a regular dividend.
https://www.5iresearch.ca/blog/brookfield-infrastructure-partners-bipun-vs-bipc
What’s the difference? (BIPC vs BIP.UN & BEPC vs BEP.UN)
In short, Brookfield created official Canadian entities with BIPC and BEPC for the representative income trusts shares with one goal to make the shares more appealing to Canadian investors as BIPC and BEPC pay a dividend instead of a cash distribution. The primary difference is the tax benefit for Canadians to own BIPC and BEPC over the other shares.
This is a snippet from Brookfield:
Class A shares of BIPC are structured to provide an economic return equivalent to BIP units though a traditional corporate structure. Each BIPC Class A share has same distribution as a BIP unit, and is exchangeable, at the shareholders option, for one BIP unit.
While the dividend from the corporation is equal to the distribution from the income trust, the after-tax benefit could be better with BIPC or BEPC depending on the account you hold it. For selection simplicity, if you plan to hold one of them in a non-registered account go with the corporation.
The shares are not equal as in you cannot swap back and forth. The BIP.UN and BEP.UN cannot be exchanged for the BIPC and BEPC shares. Brookfield did a one time transfer to setup the corporation and after that you can transfer your corporate shares back into income trust shares but not the other way around.
BIP.UN or BIPC – BEP.UN or BEPC – Which one should you own?
Due to the benefits of the dividends, the stock prices of the corporate shares vs the income trust shares have already differed. Since the payout is the same in dividends or distribution, the yield is, however, different and will probably always be different.
Will the corporate shares always be more expensive because of the tax incentive in a non-registered account? If so, plan to hold the corporate shares (BIPC or BEPC) in a non-registered and the income trust shares (BIP.UN or BEP.UN) in the other accounts.
The corporate shares should only vary due to the tax incentive if they are the same business.
→ Toma atenção às mudanças na fiscalidade nos US sobre os PTPs (incluindo os BEP e BIP):
https://helpcentre.trading212.com/hc/en-us/articles/8252397565213-Publicly-Traded-Partnerships-PTP-Update-December-2022
De experiência, os pagamentos das entidades da Brookfield (BAM/BEP/BIP) serão interessantes, mas vendi-os devido a constantes atrasos e alguma confusão sobre a tipologia nos pagamentos, que vinham separados em várias categorias, com retenção de imposto mas apareciam como se não foram retidos impostos.
Atenção que as Bermudas levam com 35% de imposto em Portugal (lista dos países, territórios e regiões com regimes de tributação privilegiada, claramente mais favoráveis):
https://dre.pt/dre/legislacao-consolidada/portaria/2004-105808897
https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs71.aspx
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