Is Brookfield Renewable Partners a Limited Partnership, Corporation or Trust?

Brookfield Renewable Partners L.P. (Brookfield Renewable Partners) is a Bermuda based limited partnership that is treated as a partnership for Canadian tax purposes. Brookfield Renewable Partners is not a corporation or a trust.

Is Brookfield Renewable Partners a Master Limited Partnership?

Brookfield Renewable Partners does not have the same tax consequences of a U.S. Master Limited Partnership. There is no U.S. source business income that flows out to investors. There is no ECI (Effectively Connected Income), CAI (Commercial Activity Income) or UBTI (Unrelated Business Taxable Income). For a non-U.S. resident, there are no U.S. tax filings or U.S. income tax liabilities that result from the ownership of a Brookfield Renewable Partners unit.

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

Brookfield Renewable Partners is a publicly traded partnership that does not earn active business income. Instead, Brookfield Renewable 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 Renewable Partners eligible for Tax-Deferred Plans?

In Canada, Brookfield Renewable 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 Renewable Partners' taxation year (December 31), the Canadian taxable income of Brookfield Renewable 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.

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.

Registered Canadian unitholders will receive a T5013 directly from Brookfield Renewable Partners. If you are a registered Canadian resident holder and did not receive your Form T5013 for the previous taxation year please contact (877) 209-9981 or at www.taxpackagesupport.com/BEP.

When will I receive my Tax Form (T5013)?

Brookfield Renewable 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?

No, we cannot send a replacement form. 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.

I am a Canadian resident. Is the distribution I am paid from Brookfield Renewable Partners subject to Withholding Tax?

If you are a Canadian resident, your distribution will likely not be subject to withholding tax.

While BEP is a Bermuda partnership, its income comes from holding companies the partnership owns. At present, these holdings companies are either in Canada or Bermuda, and we do not expect this to change for the foreseeable future. For payments from a Bermuda company to a Canadian resident, there is no withholding tax as Bermuda does not charge withholding taxes. In addition, there is no withholding tax on payments from a Canadian corporation to a Canadian resident. Accordingly, if you are Canadian resident there is no withholding tax on your distributions. The currency of your distribution does not change this.

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.

I held Brookfield Renewable Power Fund prior to the 2011 Brookfield Renewable Partners reorganization. How does this impact my Adjusted Cost?

For Canadian residents, in general, a unitholder's tax cost of his/her Brookfield Renewable 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. ¹

For Canadian residents, the tax cost of units is determined in Canadian dollars so all three components should be determined in Canadian dollars. Brookfield Renewable 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 Renewable Partners units.

The website includes a schedule entitled “Brookfield Renewable Partners L.P. Adjusted Cost Base of One Unit Received on Merger (No Tax Rollover)” that contains information to assist a unitholder in computing the adjusted cost base of their Brookfield Renewable Partners units. That schedule reflects the adjusted cost base to a holder of one original unit received on the merger in November 2011 that did not file a Tax Election and did not reinvest distributions in additional units under the distribution reinvestment plan. Had any distributions been reinvested under the distribution reinvestment plan such amounts would be added to the adjusted cost base. A former Brookfield Renewable Power Fund unitholder that received their Brookfield Renewable Partners units as a result of the November 2011 merger and filed a Tax Election should start the adjusted cost base calculation with the adjusted cost base of their Brookfield Renewable Power Fund units immediately prior to the merger instead of the CDN$25.53 value of a Brookfield Renewable Energy unit used in the schedule that is applicable to a unitholder that did not file a Tax election. Additional historical information is available on the website to assist a unitholder with the computation of their Brookfield Renewable Power Fund units adjusted cost base immediately prior to the November 2011 merger.

What is Brookfield Renewable Partners’ Partnership ID Number?

Brookfield Renewable Partners’ Canadian tax identification number (Business Number) is 833644305RZ0001.

What does BMU on box 135 signify?

BMU identifies the source of the income as Bermuda.

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. If the field cannot be left blank, one option is to use code 221111 which comprises companies primarily engaged in the generation of electricity using hydroelectric generation. 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 Renewable Partners’ TS number?

Brookfield Renewable 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 Renewable 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 Renewable 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 Renewable Partners’ Quebec Tax ID Number?

Brookfield Renewable Partners does not have a Quebec number because it is non-resident.

Are units considered foreign property for the purposes of the Canada Revenue Agency T-1135 Form – Foreign Income Verification Statement?

No.

I owned units of Brookfield Renewable Partners L.P. prior to the formation of Brookfield Renewable Corporation. As a result of the special distribution from Brookfield Renewable Partners L.P. in 2020, I received class A shares of Brookfield Renewable 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 Renewable 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 Renewable Partners L.P. by an amount equal to the fair market value at the time of the special distribution of the class A shares of Brookfield Renewable Corporation (“BEPC Shares”) you have received. The same fair market value at the time of the special distribution of the BEPC Shares is your adjusted cost basis in your BEPC Shares. The closing price of a share of Brookfield Renewable Corporation on the New York Stock Exchange on July 30, 2020 (the date of the special distribution) was US$40.72. The Bank of Canada daily exchange rate for July 30^th, 2020 for USD/CAD was 1.3432.

Please note that the above numbers are calculated based on the number of Class A Shares of Brookfield Renewable Corporation at the time of the special distribution and have not been updated for any subsequent stock splits.

Is Brookfield Renewable Partners a Limited Partnership, Corporation or Trust?

Brookfield Renewable Partners is a Bermuda based limited partnership that is treated as a partnership for U.S. tax purposes. Brookfield Renewable Partners is not a corporation or a trust.

Is Brookfield Renewable Partners a Master Limited Partnership?

Brookfield Renewable Partners does not have the same tax characteristics of a U.S. Master Limited Partnership. There is no U.S. source income that flows out to investors that would cause U.S. federal, state and local income tax filing obligations. There is no UBTI (Unrelated Business Taxable Income).

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

Brookfield Renewable Partners is a publicly traded partnership that does not earn active business income. Instead, Brookfield Renewable 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 Renewable Partners’ distributions are eligible to be treated as nontaxable return of capital distributions for U.S. tax purposes. A significant portion of Brookfield Renewable Partners’ dividends are “qualified dividends” and therefore eligible for a preferential U.S. income tax rate (for individuals). ²

What is Brookfield Renewable Partners’ Partnership ID Number?

Brookfield Renewable Partners’ U.S. tax identification number (Employer Identification Number) is 98-1015903.

Is Brookfield Renewable Partners eligible for Tax-Deferred Plans?

In the U.S., units of Brookfield Renewable Partners qualify for IRA and 401(k) accounts.

What Tax Form will I receive as a U.S. Unitholder?

After the end of Brookfield Renewable Partners' taxation year (December 31), the U.S. taxable income of Brookfield Renewable 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 (not a Form 1099).

In general, the distributions you receive should equal your pro-rate share of the sum of (i) the net of all income and expenses and (ii) return of capital, reported on Schedule K-1. There may be minor differences due to exchange rates.

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 who are U.S. residents or who may have U.S. tax reporting obligations. We expect to provide Schedule K-1 tax information via our online portal by mid-March, 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 (877) 209-9981 or at www.taxpackagesupport.com/BEP. Alternatively, use the link to Tax Package Support at the right side of this page.

Please note that no Schedule K-1 forms were issued in 2012 for the 2011 tax year, or for any prior year. The first time Brookfield Renewable Partners was required to issue Schedule K-1s was for its 2012 taxation year, which were issued in March 2013.

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 (877) 209-9981. 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 (877) 209-9981 or www.taxpackagesupport.com/BEP 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 (877) 209-9981 or www.taxpackagesupport.com/BERP 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 Renewable Partners subject to Withholding Tax?

If you are a U.S. unitholder, the effective withholding tax rate on your distributions should be approximately 7.5% (approximately 50% of distributions multiplied by a 15% withholding tax). This rate is based on management estimates and will vary from year to year. Further, it is based on withholding tax rates for taxable investors in the U.S. Withholding tax rates may vary for tax exempt entities.

While Brookfield Renewable Partners is a Bermuda partnership, its income comes from holding companies the partnership owns. At present, these holdings companies are either in Canada or Bermuda, and we do not expect this to change for the foreseeable future. The income Brookfield Renewable Partners earns from underlying subsidiaries includes dividends and interest paid by subsidiaries in jurisdictions that levy withholding tax. Since Brookfield Renewable Partners is a "flow-through" for U.S. income tax purposes, a portion of the income may be subject to withholding taxes levied by jurisdictions such as the U.S.

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 Renewable Partners’ transfer agent in the case of registered unitholders) with the appropriate tax form.

What is my Adjusted Cost Basis?

For U.S. residents, in general, a unitholder's tax cost of his/her Brookfield Renewable 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.

The schedules distributed with Schedule K-1 compute the tax cost of Brookfield Renewable Partners units for U.S. residents.

Brookfield Renewable 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 Renewable Partners units.

Is Brookfield Renewable Partners considered Passive Foreign Investment Company (PFIC) or Controlled Foreign Corporation (CFC)?

Brookfield Renewable Partners is not considered a PFIC or CFC for U.S. tax purposes and therefore ownership of Brookfield Renewable Partners units do not generate any PFIC or CFC related filings or tax liabilities.

Does Brookfield Renewable Partners generate UBTI?

No, we do not generate UBTI.

I owned units of Brookfield Renewable Partners L.P. prior to the formation of Brookfield Renewable Corporation. As a result of the special distribution from Brookfield Renewable Partners L.P. in 2020, I received class A shares of Brookfield Renewable Corporation. Is this special distribution taxable for U.S. federal income tax purposes?

Brookfield Renewable Partners L.P. is expected to qualify as an “investment partnership” so that the special distribution of class A shares of Brookfield Renewable Corporation to a U.S. unitholder who is an “eligible partner” qualifies as a non-taxable distribution of property.

The initial 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 Renewable Partners L.P.’s adjusted tax basis in such class A shares immediately before the distribution of $48.304 per share, subject to certain adjustments, and (ii) such U.S. unitholder’s adjusted tax basis in its interest in Brookfield Renewable Partners L.P. units reduced by the amount of any cash received in lieu of fractional class A shares pursuant to the special distribution. In relation to the adjustments mentioned in (i), such adjustments will be made available on each investor’s K-1 information slip and we expect that such adjustments will be immaterial to nearly all BEP unitholders, except for those unitholders with large holdings (e.g. greater than 50,000 units).

Please note that the above numbers are calculated based on the number of Class A Shares of Brookfield Renewable Corporation at the time of the special distribution and have not been updated for any subsequent stock splits.

Is Brookfield Renewable Partners a Limited Partnership, Corporation or Trust?

Brookfield Renewable Partners is a Bermuda based limited partnership. Brookfield Renewable Partners is not a corporation or a trust.

Is Brookfield Renewable Partners a Master Limited Partnership?

Brookfield Renewable Partners does not have the same tax consequences of a U.S. Master Limited Partnership. There is no U.S. source business income that flows out to investors. There is no ECI (Effectively Connected Income) or UBTI (Unrelated Business Taxable Income). For non-U.S. residents, there are no U.S. tax filings or U.S. income tax liabilities that result from the ownership of a Brookfield Renewable Partners unit.

Does ownership of Brookfield Renewable Partners units result in U.S. tax consequences for European unitholders?

Brookfield Renewable Partners has no U.S. source income or business and as such European unitholders do not have to file any U.S. federal or state tax returns. European unitholders are not exposed to U.S. income tax as a result of owning Brookfield Renewable Partners units.

Brookfield Renewable Partners units do not generate any of the following U.S. tax consequences which may be adverse to prospective unitholders on a disposition of units:

• U.S. Source Income
• U.S. State or Federal Income Tax Filings
• MLP related filings
• Effectively Connected Income (ECI), Commercial Activity Income (CAI), Unrelated Business Taxable Income (UBTI)
• Foreign Investment Real Property Tax Act (FIRPTA) related filings

Does Brookfield Renewable Partners generate any Unrelated Business Taxable Income (UBTI)?

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

Has Brookfield Renewable Partners generated or is it expected to generate Effectively Connected Income (ECI)?

No, Brookfield Renewable Partners has not and is not expected to generate effectively connected income (ECI). Furthermore, Brookfield Renewable Partners does not directly own any assets used in a U.S. trade or business. Brookfield Renewable 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 Renewable 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 Renewable Partners publicly traded units may be subject to FIRPTA taxation on a disposition of their units.

I am a European resident. Is the distribution I am paid from Brookfield Renewable Partners subject to Withholding Tax?

If you are a European unitholder, the effective withholding tax rate on your distributions should be approximately 7.5% (approximately 50% of distributions multiplied by a 15% withholding tax). This rate is based on management estimates and will vary from year to year. Further, it is based on withholding tax rates for taxable investors in most European countries (UK, Ireland, Switzerland, Netherlands). Withholding tax rates may vary for tax exempt entities.

While Brookfield Renewable Partners is a Bermuda partnership, its income comes from holding companies the partnership owns. At present, these holdings companies are either in Canada or Bermuda, and we do not expect this to change for the foreseeable future. The income Brookfield Renewable Partners earns from underlying subsidiaries includes dividends and interest paid by subsidiaries in jurisdictions that levy withholding tax. Since Brookfield Renewable Partners is a "flow-through" for U.S. income tax purposes, a portion of the income may be subject to withholding taxes levied by jurisdictions such as the U.S.

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 Renewable Partners’ transfer agent in the case of registered unitholders) with the appropriate tax form.

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 source interest and dividends earned from subsidiaries that, when paid to a non-Canadian unitholder, are subject to varying rates of Canadian withholding taxes ranging from nil to 25%.