pubdate: zone: page: user: time: color: the economic times...feb 11, 2019  · talks on to include...

1
Sugata.Ghosh@timesgroup.com Mumbai: Many well-heeled Indi- ans who own stocks and properti- es abroad or are beneficiaries of offshore trusts may come under the glare of the income tax (I-T) department for failing to spell out their ‘indirect investments’. Indirect investments are the next- level investments — or, holdings in other overseas companies — by the entity in which the resident Indian is a stakeholder. Consider an indivi- dual holding 15% equity interest in an unlisted offshore firm (A) in Du- bai, which in turn is a shareholder in three US companies (B, C and D). According to the department, in- direct ownership in B, C and D has to be disclosed in the income tax re- turn along with the investment in A. The tax office, sources said, has asked a few “high-profile individu- als” to explain why they did not dis- close their indirect investments be- cause under the law the Indian re- sident is the ultimate beneficial owner (UBO) of all the companies. Non-disclosure of information co- uld attract a penalty of at least ` 10 lakh; and, if the taxman is not satis- fised with the response, it can invo- ke the new law against black money. “To define the term ‘beneficial ownership’, Section 139 of the Inco- me tax Act was amended. The new definition, which attempted to co- ver indirect ownership as well, ca- me into effect from April 1, 2016. As a result, investment in a structure outside India which in turn has made downstream investments in other structures world over is be- ing covered under the new clause. So long as the Indian resident has substantial stake or voting power or control over board to decide the downstream investment may be covered under the amended defini- tion. However, I feel, the definition is being interpreted too widely. Should any investment in any structure, in India or outside India which makes downstream invest- ments in the US, Cayman or Ire- land, be covered under the amen- ded definition? It may not be legal- ly correct,” said senior chartered accountant Dilip Lakhani. Cases of Downstream Investments18 Taxman Goes After Indirect Investments in Overseas Cos Indian residents may face tax scrutiny for non-disclosure of such info under beneficial ownership law Today on Going, going, gone— cheap airfares Slack goes for an IPO, but enterprise chat remains a hard sell How a drug-pricing regulator was reduced to a paper tiger FIs, banks, HNIs set to sign up; RIL will buy back asset after 20 years from InvIT ICICI Prudential Asset Mana- gement Company and the fami- ly office of the Poonawallas of Serum Institute are likely to jo- in the Canadian investor in In- dia Infrastructure Trust, the ve- hicle that is being created for the acquisition to take over the 1,400 km com- mon carrier pi- peline from Ka- kinada on the east coast to Bharuch in Gu- jarat, said peo- ple aware of the development. Three or four more ultra-high net worth individuals like Uday Kotak or their family offices too are expected to join the consor- tium, added the people mentio- ned above. Talks on to Include Banks too18 Arijit.Barman @timesgroup.com Mumbai: A set of marquee as- set management companies, fa- mily offices, banks and insurers are said to be interested in parti- cipating in the Brookfield-led infrastructure investment trust (InvIT) that is buying the loss- making East West Pipeline Ltd (EWPL), earlier known as Reli- ance Gas Transportation In- frastructure Ltd, for an enter- prise valuation of . `13,000 crore ($2 billion). . `13,000-CR AMBANI GAS PIPELINE DEAL In Transit EWPL is a private co of Mukesh Ambani & family It has 1,386-km pipeline from Kakinada in Andhra Pradesh to Bharuch in Gujarat with capacity to transport up to 85 mmscmd of natural gas It transported around 6 billion standard cubic meters of natural gas in FY18 FY18 Financials Loss: ` 715 cr Revenue: ` 884 cr India Infra- structure Trust to be InvIT vehicle Brookfield to own 85-90% & manage asset; co-investors will have the rest `6,500 cr each to be paid in debt & equity Brookfield also keen on similar structure for Jio’s optic fibre & tower assets Analjit Singh, founder of the $3-billion Max Group, is set be appointed as non-executive chairman of Max Life Insur- ance Company and Max India, reports Arun Kumar. 7 Analjit to be Non-Exec Chairman MAX LIFE INSURANCE AND MAX INDIA Do you think the Rafale row will hit Modi’s credentials as corruption fighter? www.economictimes.com Is EPF or income tax data a reliable gauge to measure job generation? TODAY’S QUESTION 26% YES 72% NO 2% CAN’T SAY BRANDS: CREATING DESIRE 5 Under Scanner INDIRECT OWNERSHIP An Indian resident buys stake in an offshore company A Firm A buys stake in three other companies B, C and D Indirect ownership in B, C & D has to be disclosed in I-T return along with investment in A, says tax dept EXPERT TAKE Definition of beneficial ownership that also covers indirect ownership is too wide It could lead to disputes; more clarity needed from CBDT % The Central Provident Fund Commissioner (CPFC) has stepped in to help middle-class people whose investments in IL&FS group compa- nies via standalone trustees are at risk, reports Saikat Das. 12 CPFC Seeks Info on IL&FS Exposure PF BODY WRITES TO EXEMPTED TRUSTS Raghav.Ohri @timesgroup.com New Delhi: The parliamentary standing committee on informa- tion technology is exploring ways of expressing its frustration, in- cluding declaring breach of privi- lege, at being unable to get Twitter CEO Jack Dorsey or his second- in-command to attend its hearing on Monday, said people with knowledge of the matter. This may include sending a “strong” recommendation to the govern- ment seeking adverse action, they said. The commit- tee will decide what “action” can be taken against Twitter, they ad- ded. The panel had summoned repre- sentatives of Twitter and the Ministry of Elec- tronics and Information Techno- logy to be present before it on Monday at 3 pm to examine the is- sue of “safeguarding citizens’ rights on social media/online news platforms”. Twitter said it wouldn’t be able to get Dorsey, who was recently in India, to the country on time. “Given the short notice of the hearing, we informed the com- mittee that it would not be possib- le for senior officials from Twit- ter to travel from the United Sta- tes to appear on Monday,” Twitter had said on Saturday. “Our CEO, Jack Dorsey, and other senior Twitter executives visited India in recent weeks because it is an important market for Twitter and we value the growing interest in Twitter in India.” ‘Shying Away from Responsibility’18 House Panel may Troll Twitter Strong Reaction Parliamentary panel exploring all options including issuing breach of privilege to passing strong recommendations against Twitter They were called since Indian represen- tatives lack mandate to frame policy or enforce it Discussion aimed at pinning respons- ibility Panel refuses to delay interaction with CEO Dorsey or his deputy to March-April as demanded by co Explores tough action against company for not sending CEO to its meeting today Twitter said it wouldn’t be able to get CEO Dorsey to India on time as per the panel’s summons Gender Parity Crucial for World: Gillard Our Bureau Mumbai: It’s not often that you see a presentation on the challenges of mountaineering expeditions being followed by a discussion on the diversity of corporate boards. That was the range of ideas explored at the second edition of the ET Women’s Forum in Mumbai. What’s more, the lineup of speakers who took the stage couldn’t have been more varied – entrepreneurs, bankers, social workers, athletes, cops and philanthropists. Their remarkable achievements are a strong indicator of how much more women could do if only the playing field was levelled. As Ruth Bader Ginsburg, the trailblazing US Supreme Court justice, said, “I ask no favour for my sex; all I ask of our brethren is to take their feet off our necks.” Women far outnumbered men both on stage and ET Women’s Forum marks a key step in advancing discourse on equal world Paytm Tops UPI Charts, Just Ahead of Google Pay, PhonePe Pratik.Bhakta@timesgroup.com Bengaluru: Paytm led in Unified Payments Interface (UPI) transac- tions in January, closely followed by Google Pay and PhonePe, according to people with knowledge of the matter. As UPI gains further ground, the field is competitive –– Paytm clocked more than 221 million transactions, while Google Pay and PhonePe were at about 220 million, said the people cited above. PhonePe, however, told ET that across all payment modes, it had 225 million transactions worth `30,000 crore in January. While the National Payments Corpo- ration of India (NPCI) issues overall UPI transaction numbers, ET has sourced the individual split of the top three largest payment players from multiple sources. Overall, UPI clocked around 672 million transactions last month, up from 620 million in Decem- ber. Google Pay did not provide specif- ic numbers and Paytm didn’t respond to queries. Even as the number of transactions has jumped, peer to peer (P2P) transac- tions still dominate. “As per internal calculations, the total number of mer- chant transactions is not more than 100 to 120 million per month,” said a senior banker on condition of anonymity. BHIM Losing Steam18 UPI logged 672million transcations in Jan, of which Paytm accounted for over 221 million Transaction Count Source: NPCI Bharat Interface For Money Month Volume (Million) Value (`) January 672.75 1. 09 lakh cr December 620.17 1. 02 lakh cr November 524. 94 82, 232 cr Month Volume (Million) Value (`) January 13. 9 6202. 5 cr December 17. 06 7589.1 cr November 17. 35 7981. 8 cr Unified Payments Interface Wipro for Data Localisation, Goes against Nasscom Stand Wipro has favoured mandatory domestic incorporation and data localisation. But its response is in stark contrast to Nasscom, which said local incorporation need is arbitrary. Disruption: Startups & Tech6 llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll Artificial Intelligence is Like a Book that Writes Itself: Sebastian Thrun Recent advances in AI have given computers the ability to program themselves, says Sebastian Thrun, CEO, Kittyhawk Corporation. AI is like a book that writes itself, says Thrun. He will be a speaker at this year’s Global Business Summit. Companies & Economy8 llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll Pilot Crunch Hits IndiGo Ops, Over 50 Flights Cancelled Over 2 Days Budget carrier IndiGo has cancelled more than 50 flights from various airports across the country in the past two days owing to a shortage of pilots, especially captains. The airline is likely to cancel about 30 flights on Monday. Companies & Economy8 llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll Aircel Files Contempt Petition Against DoT for `298-cr Dues Bankrupt telco Aircel has filed a contempt of court petition in the SC against DoT, including secretary Aruna Sundararajan, for failing to refund `298 crore despite repeated orders. Companies: Pursuit of Profit17 llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll PMO Approves Several Measures to Meet 15% EV Target in 5 Years The Prime Minister’s Office (PMO) has given its go-ahead to at least a dozen measures proposed by a committee of secretaries to help the coun- try achieve a 15% share of electric vehicles in total vehicle sales in the next five years. Economy: Macro, Micro & More 19 Inside story in the audience and the discussions ran the entire gamut of arguments to fully realise the potential of half our population. Julia Gillard, the former PM of Australia and the first and only woman in that position, reminded us in her inaugural address why gender parity is crucial: “A gender-equal world is better for both men and women.” Over 40 speakers and 450 delegates participated in the day-long forum on Friday. ‘Diverse Boards are Beneficial to Cos’18 MORE REPORTS 13, 14, 15, 16 (From left) Independent director Ireena Vittal, 30% Club’s Brenda Trenowden, ex-Axis Bank chief Shikha Sharma and former Australian PM Julia Gillard at the forum MUMBAI | 22 + 4 PAGES OF ET PANACHE | *. `3.00 OR . `7.00 ALONG WITH THE TIMES OF INDIA BRANDS: CREATING DESIRE 5 SPORTS: THE GREAT GAMES 22 AROUND THE WORLD 21 BENNETT, COLEMAN & CO. LTD. T HE E CONOMIC T IMES WWW.ECONOMICTIMES.COM ITC to Start Ecomm Ops for Niche FMCG Products US Shutdown Talks Stall over Immigrant Policies New Zealand Beat India by 4 Runs, Win T20 Series MONDAY, 11 FEBRUARY 2019 Sebi nod is expected in the coming weeks for the InvIT and the transaction is likely to close by month-end 5 Investors may Join Brookfield for East West Buy BHARAT CHANDA Z 13 per month MOVIES NOW, TIMES NOW, ROMEDY NOW, ET NOW. MNX MIRROR NOW & ZOOM. nm...wk.a, A f x ` y 3 \ L T I lull Pullman New Delhi Aerocity combines the best of services , design , amenities and cuisines, for when you mean business and when you simply wish to disconnect in leisure. 12 , 712sg ft Pillarless Ballroom pullmca rl HOT... AND ASSO RTS NEW DELHI AEROCITY AN ACCOR HOTELS EXPERIENCE PULLMANDELHIAEROCITY.COM

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Page 1: PubDate: Zone: Page: User: Time: Color: THE ECONOMIC TIMES...Feb 11, 2019  · Talks on to Include Banks too($2 billion). 18 Arijit.Barman @timesgroup.com Mumbai: A set of marquee

[email protected]

Mumbai: Many well-heeled Indi-ans who own stocks and properti-es abroad or are beneficiaries ofoffshore trusts may come underthe glare of the income tax (I-T)department for failing to spell outtheir ‘indirect investments’.

Indirect investments are the next-level investments — or, holdings inother overseas companies — by theentity in which the resident Indianis a stakeholder. Consider an indivi-dual holding 15% equity interest inan unlisted offshore firm (A) in Du-bai, which in turn is a shareholderin three US companies (B, C and D).

According to the department, in-direct ownership in B, C and D hasto be disclosed in the income tax re-turn along with the investment inA. The tax office, sources said, hasasked a few “high-profile individu-als” to explain why they did not dis-

close their indirect investments be-cause under the law the Indian re-sident is the ultimate beneficialowner (UBO) of all the companies.

Non-disclosure of information co-uld attract a penalty of at least `̀10lakh; and, if the taxman is not satis-

fised with the response, it can invo-ke the new law against black money.

“To define the term ‘beneficialownership’, Section 139 of the Inco-me tax Act was amended. The newdefinition, which attempted to co-ver indirect ownership as well, ca-me into effect from April 1, 2016. Asa result, investment in a structureoutside India which in turn hasmade downstream investments inother structures world over is be-ing covered under the new clause.So long as the Indian resident hassubstantial stake or voting poweror control over board to decide thedownstream investment may becovered under the amended defini-tion. However, I feel, the definitionis being interpreted too widely.Should any investment in anystructure, in India or outside Indiawhich makes downstream invest-ments in the US, Cayman or Ire-land, be covered under the amen-ded definition? It may not be legal-ly correct,” said senior charteredaccountant Dilip Lakhani.

Cases of Downstream Investments��18

Taxman Goes After IndirectInvestments in Overseas Cos Indian residents mayface tax scrutiny fornon-disclosure of suchinfo under beneficialownership law

Today on

Going, going, gone— cheap airfares

Slack goes for an IPO, but enterprise chatremains a hard sell

How a drug-pricing regulator wasreduced to a paper tiger

FIs, banks, HNIs setto sign up; RIL willbuy back asset after20 years from InvIT

ICICI Prudential Asset Mana-gement Company and the fami-ly office of the Poonawallas ofSerum Institute are likely to jo-in the Canadian investor in In-dia Infrastructure Trust, the ve-hicle that is being created for the

acquisition totake over the1,400 km com-mon carrier pi-peline from Ka-kinada on theeast coast toBharuch in Gu-jarat, said peo-ple aware of thedevelopment.

Three or four more ultra-highnet worth individuals like UdayKotak or their family offices tooare expected to join the consor-tium, added the people mentio-ned above.

Talks on to Include Banks too��18

[email protected]

Mumbai: A set of marquee as-set management companies, fa-mily offices, banks and insurersare said to be interested in parti-cipating in the Brookfield-ledinfrastructure investment trust(InvIT) that is buying the loss-making East West Pipeline Ltd(EWPL), earlier known as Reli-ance Gas Transportation In-frastructure Ltd, for an enter-prise valuation of .̀ 13,000 crore($2 billion).

.̀ 13,000-CR AMBANI GAS PIPELINE DEAL

In TransitEWPL is a private co of

Mukesh Ambani & family

It has 1,386-km pipeline from Kakinada

in Andhra Pradesh to

Bharuch in Gujarat with

capacity to transport up to

85 mmscmd of natural gas

It transported around

6 billion standard cubic meters of natural gasin FY18

FY18Financials

Loss: `715 cr Revenue:`884 cr

India Infra-

structure Trust to

be InvIT vehicle

Brookfield to own

85-90% & manage

asset; co-investors

will have the rest

`6,500 cr each to be

paid in debt & equity

Brookfield also keen

on similar structure

for Jio’s optic fibre &

tower assets

Analjit Singh, founder of the $3-billion Max Group, is set beappointed as non-executive chairman of Max Life Insur-ance Company and Max India, reports Arun Kumar. ��7

Analjit to be Non-Exec ChairmanMAX LIFE INSURANCE AND MAX INDIA

Do you think the Rafale row will hit Modi’scredentials as corruption fighter?

www.economictimes.com

Is EPF or income tax data a reliable gaugeto measure job generation?

TODAY’S QUESTION

26%YES

72%NO

2%CAN’T SAY

BRANDS: CREATING DESIRE ��5

Under ScannerINDIRECT OWNERSHIP

An Indian resident buys stake in an offshore company A

Firm A buys stake in three other companies B, C and D

Indirect ownership in B, C & D has to be disclosed in I-T return along with investment in A, says tax dept

EXPERT TAKE

Definition of beneficial ownership that also

covers indirect ownership is too wide

It could lead to disputes; more clarity

needed from CBDT

%

The Central Provident Fund Commissioner (CPFC) has stepped in tohelp middle-class people whose investments in IL&FS group compa-nies via standalone trustees are at risk, reports Saikat Das. ��12

CPFC Seeks Info on IL&FS Exposure PF BODY WRITES TO EXEMPTED TRUSTS

[email protected]

New Delhi: The parliamentarystanding committee on informa-tion technology is exploring waysof expressing its frustration, in-cluding declaring breach of privi-lege, at being unable to get TwitterCEO Jack Dorsey or his second-in-command to attend its hearing

on Monday, said people withknowledge of the matter. Thismay include sending a “strong”recommendation to the govern-ment seeking adverse action, they

said. The commit-tee will decidewhat “action” canbe taken againstTwitter, they ad-ded.

The panel hadsummoned repre-sentatives ofTwitter and theMinistry of Elec-

tronics and Information Techno-logy to be present before it onMonday at 3 pm to examine the is-sue of “safeguarding citizens’

rights on social media/onlinenews platforms”.

Twitter said it wouldn’t be ableto get Dorsey, who was recently inIndia, to the country on time.

“Given the short notice of thehearing, we informed the com-mittee that it would not be possib-le for senior officials from Twit-ter to travel from the United Sta-tes to appear on Monday,” Twitterhad said on Saturday. “Our CEO,Jack Dorsey, and other seniorTwitter executives visited Indiain recent weeks because it is animportant market for Twitter andwe value the growing interest inTwitter in India.”

‘Shying Away from Responsibility’��18

House Panel may Troll TwitterStrong ReactionParliamentary panel exploring all options including issuing breach of privilege to passing strong recommendations against Twitter

They were calledsince Indian represen-tatives lack mandate to frame policy or enforce it

Discussion aimed at pinningrespons-ibility

Panel refusesto delay interaction with CEO Dorsey or his deputy to March-April as demanded by co

Explores tough actionagainst company fornot sending CEO toits meeting today Twitter said

it wouldn’t be

able to get

CEO Dorsey

to India on

time as per

the panel’s

summons

Gender Parity Crucial for World: Gillard

Our Bureau

Mumbai: It’s not often that you see a presentationon the challenges of mountaineering expeditionsbeing followed by a discussion on the diversity ofcorporate boards. That was the range of ideasexplored at the second edition of the ET Women’sForum in Mumbai. What’s more, the lineup ofspeakers who took the stage couldn’t have beenmore varied – entrepreneurs, bankers, socialworkers, athletes, cops and philanthropists.

Their remarkable achievements are a strongindicator of how much more women could do ifonly the playing field was levelled. As Ruth BaderGinsburg, the trailblazing US Supreme Courtjustice, said, “I ask no favour for my sex; all I ask ofour brethren is to take their feet off our necks.”

Women far outnumbered men both on stage and

ET Women’s Forum marks a key step in advancing discourse on equal world

Paytm Tops UPI Charts, JustAhead of Google Pay, PhonePe

[email protected]

Bengaluru: Paytm led in UnifiedPayments Interface (UPI) transac-tions in January, closely followed byGoogle Pay and PhonePe, according topeople with knowledge of the matter.As UPI gains further ground, the fieldis competitive –– Paytm clocked morethan 221 million transactions, whileGoogle Pay and PhonePe were at about220 million, said the people citedabove. PhonePe, however, told ET thatacross all payment modes, it had 225million transactions worth `30,000crore in January.

While the National Payments Corpo-ration of India (NPCI) issues overallUPI transaction numbers, ET hassourced the individual split of the topthree largest payment players frommultiple sources. Overall, UPI clockedaround 672 million transactions lastmonth, up from 620 million in Decem-

ber. Google Pay did not provide specif-ic numbers and Paytm didn’t respondto queries.

Even as the number of transactionshas jumped, peer to peer (P2P) transac-tions still dominate. “As per internalcalculations, the total number of mer-chant transactions is not more than 100to 120 million per month,” said a seniorbanker on condition of anonymity.

BHIM Losing Steam��18

UPI logged 672milliontranscations in Jan, ofwhich Paytm accountedfor over 221million

Transaction Count

Source: NPCI

Bharat Interface For Money

Month Volume (Million) Value (`)

January 672.75 1.09 lakh cr

December 620.17 1.02 lakh cr

November 524.94 82,232 cr

Month Volume (Million) Value (`)

January 13.9 6202.5 cr

December 17.06 7589.1 cr

November 17.35 7981.8 cr

Unified Payments Interface

Wipro for Data Localisation, Goesagainst Nasscom StandWipro has favoured mandatory domesticincorporation and data localisation. But itsresponse is in stark contrast to Nasscom, whichsaid local incorporation need is arbitrary.Disruption: Startups & Tech��6

llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll

Artificial Intelligence is Like a Bookthat Writes Itself: Sebastian ThrunRecent advances in AI have given computers theability to program themselves, says SebastianThrun, CEO, Kittyhawk Corporation. AI is like abook that writes itself, says Thrun. He will be aspeaker at this year’s Global Business Summit.Companies & Economy��8

llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll

Pilot Crunch Hits IndiGo Ops, Over50 Flights Cancelled Over 2 DaysBudget carrier IndiGo has cancelled more than50 flights from various airports across thecountry in the past two days owing to a shortageof pilots, especially captains. The airline is likelyto cancel about 30 flights on Monday.Companies & Economy��8

llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll

Aircel Files Contempt PetitionAgainst DoT for ̀̀ 298-cr Dues Bankrupt telco Aircel has filed a contempt ofcourt petition in the SC against DoT, includingsecretary Aruna Sundararajan, for failing torefund ̀̀ 298 crore despite repeated orders.Companies: Pursuit of Profit��17

llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll

PMO Approves Several Measuresto Meet 15% EV Target in 5 YearsThe Prime Minister’s Office (PMO) has given itsgo-ahead to at least a dozen measures proposedby a committee of secretaries to help the coun-try achieve a 15% share of electric vehicles intotal vehicle sales in the next five years.Economy: Macro, Micro & More ��19

Inside story

in the audience and the discussions ran theentire gamut of arguments to fully realisethe potential of half our population. JuliaGillard, the former PM of Australia and thefirst and only woman in that position,reminded us in her inaugural address whygender parity is crucial: “A gender-equalworld is better for both men and women.”

Over 40 speakers and 450 delegatesparticipated in the day-long forumon Friday.

‘Diverse Boards are Beneficial to Cos’��18

MORE REPORTS �� 13, 14, 15, 16

(From left) Independent director Ireena Vittal, 30% Club’s

Brenda Trenowden, ex-Axis Bank chief Shikha Sharma and

former Australian PM Julia Gillard at the forum

MUMBAI | 22 + 4 PAGES OF ET PANACHE | * .̀ 3.00 OR .̀ 7.00 ALONG WITH THE TIMES OF INDIA

BRANDS: CREATING DESIRE�� 5 SPORTS: THE GREAT GAMES�� 22AROUND THE WORLD�� 21

BENNETT, COLEMAN & CO. LTD.

THE ECONOMIC TIMESWWW.ECONOMICTIMES.COM

ITC to Start Ecomm Opsfor Niche FMCG Products

US Shutdown Talks Stall over Immigrant Policies

New Zealand Beat Indiaby 4 Runs, Win T20 Series

MONDAY, 11 FEBRUARY 2019

Sebi nod is

expected in

the coming

weeks for the

InvIT and the

transaction is

likely to close

by month-end

5 Investors mayJoin Brookfieldfor East West Buy

BH

AR

AT CH

AN

DA

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L T

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