Brookfield

Brookfield Corporate Simplification: Exchangeable Shares

Important Information Regarding Tax Elections

Election Deadline

60 Days

following the Effective Date to complete the online tax election questionnaire.

Coming Soon

On June 5, 2026, a Management Information Circular (the “MIC”) was published with further detail on the combination of Brookfield Corporation (“BN”) and Brookfield Wealth Solutions Ltd. (“BWS”) (the “Transaction”) and the opportunity for Eligible Canadian Holders of BN Class A Shares to elect to receive exchangeable shares (the “Exchangeable Shares”) in Brookfield Canada Corporation (“New BNC”) as consideration for their BN Class A Shares pursuant to the Transaction.

Generally an Eligible Canadian Holder who validly makes a joint election with New BNC under Section 85 of the Income Tax Act (Canada) may obtain a full or partial deferral of any capital gain that would otherwise arise on the disposition of such Eligible Canadian Holder’s BN Class A Shares.

Eligible Canadian Holders will be able to complete an online questionnaire, once available, to support preparation of the required election forms free of charge. This site provides key details, timelines and next steps to help you prepare and make an informed decision.

Are you eligible?

You may want to file a Section 85 election if:

You are a resident of Canada for tax purposes and you are not exempt from tax.
You, or a Canadian partnership that you are a member of, own shares of BN outside of a Registered Plan.
You wish to defer tax via the election.

Not sure? Consult your tax advisor before filing.

Section 85 Joint Tax Elections

Overview

The purpose of making a Joint Tax Election is to permit Eligible Canadian Holders to fully or partially defer the tax on any capital gain realized on receiving Exchangeable Shares in New BNC as consideration for their BN Class A Shares pursuant to the Transaction. The election is made under Section 85 of the Income Tax Act (Canada) (the “Tax Act”).

For many Canadian-resident taxpayers, it can be advantageous to make the Tax Election if you are eligible and are in a position where you will realize a capital gain. However, you should seek professional advice to determine whether making the Tax Election is appropriate, considering your particular facts and circumstances. If you do not make the election, the exchange of your shares could trigger adverse tax consequences for the taxation year in which the disposition occurs.

The relevant federal income tax election form is CRA Form T2057 (or, if the Shares are held as Canadian partnership property, CRA Form T2058). Some Eligible Canadian Holders may also need to file separate election forms with their provincial taxing authority.

Some key information you will need to complete the form:

Before starting the online questionnaire, please gather the following information so you can complete it in one sitting:

  • Shareholder identity information, including legal name, address, social insurance number or business number, and, if applicable, similar information for Co-owners of the shares.
  • Confirmation of Shareholder tax status (individual, corporation, trust, partnership, etc.).
  • Confirmation of Shareholder Canadian tax residency, including whether the shareholder needs to file any provincial election forms.
  • Details of the number of BN Class A Shares transferred and the number of Exchangeable Shares that the Eligible Canadian Holder has elected to receive.
  • Adjusted cost base (ACB) information for the BN Class A Shares, including any prior tax-deferred transactions or inherited/gifted units.
  • Your Elected Amount to be reported on the election form.
  • Broker or intermediary information, if applicable. For brokers, please see the Broker process section on this page.

Key Dates & Timeline

Announcement

Date: May 26, 2026

Brookfield publishes the deal announcement.

Letter of Transmittal & Election Form

Eligible Canadian Holders, who hold registered shares (i.e., not through a broker), are required to properly complete and duly execute the Letter of Transmittal received with the MIC and Election Form before the Effective Date. Eligible Canadian Holders who do not hold registered shares (i.e., hold through a broker) should connect with their broker on completion of the Letter of Transmittal.

Effective Date / Election questionnaire opens

Date: TBD

On the Effective Date, the detailed transfer terms and FMV figures become available, and the online questionnaire opens for Eligible Canadian Holders to begin the Section 85 election process. Eligible Canadian Holders will have 60 days from the Effective Date to complete the questionnaire.

Election forms prepared

Forms prepared within 30 days of complete submission

Applicable election forms, including Form T2057 or Form T2058 and any provincial filings, will be prepared based on your questionnaire responses and shared with you within 30 days of the Shareholder submitting complete information.

Election forms signed and submitted

Shareholder to review, sign and submit forms to the relevant tax authority in accordance with the instructions provided.

Completing Your Section 85 Election

Eligible Canadian Holders will complete an online questionnaire, which will be made available on this site, to begin the Section 85 election process.

The questionnaire is designed to collect the information required to prepare your election forms and guide you through each step.

Important

You are responsible for your own tax election forms, including any applicable provincial filings. This includes ensuring the election forms are correct and complete and complying with the provisions of the Tax Act (and applicable provincial income tax law). You are responsible for reviewing, signing and filing your election forms with the CRA (or the applicable provincial taxing authority).

Failure to complete the process properly or on time may result in the Transaction being treated as a taxable disposition and/or taxes, interest or penalties for which you are responsible.

This information is general only. Shareholders should consult their own tax advisors regarding their specific circumstances.

Process Overview

  • 1Complete the Letter of Transmittal and Election Form (as discussed in the MIC) before the Effective Date.
  • 2Gather detailed information regarding your shareholdings and tax information noted above.
  • 3Complete the online questionnaire once available.
  • 4Once you have completed the questionnaire, an election package will be prepared for you, including Form T2057 or Form T2058 and any provincial filings, based on your responses.
  • 5Review, sign and submit your forms in accordance with the instructions provided.

Once a complete questionnaire and signed authorization are submitted, your election package will be prepared for your review within 30 days of submission, subject to the information you provide being complete.

Broker process

For brokers and intermediaries

A separate process will be available for brokers or intermediaries supporting multiple Eligible Canadian Holders. The process is expected to use a structured intake file or broker-specific submission workflow so information can be gathered efficiently and processed in batches.

Brokers should not submit individual shareholder questions through the general support channel unless instructed. Final broker language and submission instructions will be confirmed before launch.

Frequently Asked Questions

Who is eligible to file a Section 85 election?
Eligible Canadian Holders who receive Exchangeable Shares as consideration may be able to make a Section 85 election. Shareholders should consult their own tax advisors to confirm whether the election is available and appropriate for them.
How do I complete my Section 85 election?
First, complete the Letter of Transmittal and Election Form (as discussed in the MIC) directly if you are a registered shareholder or via your broker before the Effective Date. Then return to the Tax Election Portal to complete the online questionnaire, provide the required shareholder and tax information, review the prepared package, and follow the signing and submission instructions provided through the process.
When will I receive the prepared election package?
You will receive the applicable election package within 30 days of receiving a completed shareholder submission via the online questionnaire, subject to the information provided being complete.

Need Help?

Reach out to s85support@taxelection.ca for technical and procedural inquiries with the Tax Election Portal, and consult your own tax advisor for advice about eligibility, forms, elected amounts, deadlines, and filing requirements.