U.S. withholding tax under IRC Section 1446(f) on the disposition of Publicly Traded Partnership units

Although Granite REIT is a Publicly Traded Partnership for U.S. tax purposes, Granite REIT does not expect non-U.S. investors to be subject to U.S. tax withholding under IRC Section 1446(f) on the disposition of their units. Granite REIT expects to meet the exemption under 1446(f) as Granite REIT has not been and does not expect to be engaged in a U.S. trade or business within the meaning of Treas. Reg. Sec. 1.1446(f)-4(b)(3)(ii)(A)(2). Granite REIT intends to issue qualified notices in accordance with Treas. Reg. Sec. 1.1446(f)-4(b)(3)(iii) as applicable. Granite REIT recommends that unitholders, brokers, and withholding agents consult with their tax advisors with respect to their U.S. federal withholding tax obligations.

Granite REIT’s status as a partnership for U.S. federal income tax purpose under IRC Section 7704

Under IRC Section 7704, certain Publicly Traded Partnerships may be treated as corporations for U.S. tax purposes. Granite REIT continues to expect that it will meet the “qualifying income exception”, and therefore maintain its status as a partnership for U.S. federal income tax purposes under IRC Section 7704 in accordance with Granite’s Declaration of Trust. Granite REIT recommends that unitholders, brokers, and withholding agents consult with their tax advisors with respect to their U.S. federal tax implications.