John
We see the offer as being beneficial to certain investors, with the main difference between exchanging for BNRE shares and not exchanging is that BNRE issues Return of Capital distributions and BN issues dividends. An investor in a higher income tax bracket may prefer the RoC (BNRE) method, as this will lower their Adjusted Cost Basis of their BNRE shares, thereby only incurring capital gains tax once the investment is sold. An investor that opts to keep BN shares will continue to receive dividend payments, incurring annual dividend income tax liabilities.
There is also the potential that the liquidity of BNRE increases as investors switch to these shares, and this can increase the valuation of the company.