FORM 20-F/A Brookfield Property Partners L.P. - Brookfield Asset ...

While the BPY General Partner and the Property General Partner expect the Holding Entities to lookthroughour company and the Property Partnership in determining the rate of Canadian federal withholding taxapplicable to amounts paid by the Holding Entities to the Property Partnership, we may be unable to accurately ortimely determine the residency of our unitholders for purposes of establishing the extent to which Canadianfederal withholding taxes apply or whether reduced rates of withholding tax apply to some or all of ourunitholders. In such a case, the Holding Entities will withhold Canadian federal withholding tax from allpayments made to the Property Partnership that are subject to Canadian federal withholding tax at the rate of25%. Canadian resident unitholders will be entitled to claim a credit for such taxes against their Canadian federalincome tax liability but non-Canadian limited partners will need to take certain steps to receive a refund or creditin respect of any such Canadian federal withholding taxes withheld equal to the difference between thewithholding tax at a rate of 25% and the withholding tax at the reduced rate they are entitled to under anapplicable income tax treaty or convention. See Item 10.E. “Additional Information — Taxation — CanadianFederal Income Tax Considerations” for further detail. Investors should consult their own tax advisorsconcerning all aspects of Canadian federal withholding taxes.ITEM 4. INFORMATION ON THE COMPANY4.A. HISTORY AND DEVELOPMENT OF THE COMPANYOur company is a leading global owner, operator and investor in high quality commercial property. Weinvest in well-located real estate assets that generate, or have the potential to generate, long-term, predictable andsustainable cash flows with attractive growth and development potential in some of the world’s most resilient anddynamic markets. We seek to enhance the cash flows and value of these assets through active asset managementand our operations-oriented approach. Our properties are located in North America, Europe, Australia and Braziland we may pursue growth in other markets where we identify attractive opportunities to build operatingplatforms or acquire assets and to achieve strong risk-adjusted returns. We strive to invest at attractive valuations,particularly in distress situations that create opportunities for superior valuation gains and cash flow returns, or tomonetize assets at appropriate times to realize value.Prior to the spin-off, we will acquire from Brookfield Asset Management substantially all of itscommercial property operations, including its office, retail, multi-family and industrial assets. We will beBrookfield’s flagship public commercial property entity and the primary entity through which Brookfield AssetManagement owns and operates these businesses on a global basis. We are positioned to take advantage ofBrookfield’s global presence, providing unitholders with the opportunity to benefit from Brookfield’s operatingexperience, execution abilities and global relationships.Given the size and scope of our business, we expect that we will have significant flexibility in sourcingand allocating real estate capital on a global basis and a strong global franchise to generate growth. We plan togrow by acquiring positions of control or influence over the assets in which we invest using a variety ofstrategies to target assets directly or through portfolios and corporate entities. Our goal is to be a premier entityfor investors seeking exposure to commercial property across a wide spectrum of real estate sectors andgeographies.Our general partner and the general partner of the Property Partnership are wholly-owned subsidiaries ofBrookfield Asset Management. In addition, wholly-owned subsidiaries of Brookfield Asset Management willprovide management services to us pursuant to our Master Services Agreement.Our company was established on January 3, 2012 as a Bermuda exempted limited partnership registeredunder the Bermuda Limited Partnership Act of 1883, as amended, and the Bermuda Exempted Partnerships Actof 1992, as amended. Our company’s head and registered office is 73 Front Street, 5th Floor, Hamilton HM 12,Bermuda, and our company’s telephone number is +441 294-3304.36