Tax Information
- No distributions were made on our Class A Common Units or our Preferred Units in 2023.
- No distributions were made on our Common Units which were issued to previous holders of the Altera Unsecured Notes in 2023. Please refer to “Beneficial Holders of Altera Unsecured Notes ”.
2023 Form 8937
Cancellation of Class A Common Units, Series A Preferred Units, Series B Preferred Units and Series E Preferred Units in existence on January 6th 2023
- All Class A Common Units, Series A Preferred Units, Series B Preferred Units and Series E Preferred Units were cancelled for nil consideration on January 6th 2023.
- New Common Units were issued to holder of certain partnership Notes as at January 6th 2023. Please refer to “Beneficial Holders of Altera Unsecured Notes”.
- References to Common Units below and otherwise are to the Class A Common Units up to January 6th 2023 and thereafter to the new Common Units issued to Beneficial Holders of Altera Unsecured Notes.
Partnership Units in existence on 6th January 2023
- No distributions were made on our Common Units or our Preferred Units in 2023.
- All Class A Common Units, Series A Preferred Units, Series B Preferred Units and Series E Preferred Units were cancelled for nil consideration on January 6th 2023.
- New Common Units were issued to holder of certain partnership Notes on January 6th 2023.
- References to Common Units below and otherwise are to the Class A Common Units up to January 6th 2023 and thereafter to the new Common Units issued to Beneficial Holders of Altera Unsecured Notes.
- Refer to 2023 form 8937 for the IRC Sec. 6045B Reporting on Common Units of Altera Infrastructure L.P. in January 2023.
Tax Treatment of Partnership for Investors
The Partnership has elected to be treated as a C-Corporation for tax purposes (our investors receive the standard 1099 form and not a K-1 form).
UK Tax Strategy
Distributions
Distributions we pay to U.S. unitholders will be treated as a dividend for U.S. federal income tax purposes to the extent the distributions come from earnings and profits (“E&P”) and as a non-dividend distribution or a return of capital (“ROC”) to the extent the distributions exceed E&P.
Distributions we pay to a non-U.S. unitholder will not be subject to U.S. federal income tax or withholding tax if the non-U.S. unitholder is not engaged in a U.S. trade or business.
Please note that the determination of whether these distributions constitute a dividend from E&P or a ROC is not made for U.S. federal income tax purposes until the end of the fiscal year. If you are a U.S. unitholder and you received an IRS Form 1099 that does not set forth such amounts, you should contact your broker or tax advisor.
Holders are directed to consult their own tax advisors to determine the appropriate tax treatment with respect to the distributions.
Disclaimer:
Related comments are intended as general information only and do not constitute tax advice. This information was not written or intended to be used, and it cannot be used, by any person as a basis for avoiding federal tax penalties that may be imposed on that person. Unitholders should consult their own tax advisors with respect to the specific tax consequences to them.
Altera Infrastructure L.P. makes no warranty either expressed or implied regarding any tax issues of its unitholders.
IRC Sec. 6045B Reporting
There was no IRC Sec. 6045B Reporting for 2022.