US taxation of dividends for non-resident aliens: corporation vs master limited partnership

A US non-resident alien wishes to invest in a company: Brookfield Infrastructure. Two securities are available for this purpose: Brookfield Infrastructure Partners L.P. (NYSE: BIP), and Brookfield Infrastructure Corporation (NYSE: BIPC). The investor relations webpage says:

Class A shares of BIPC are structured to provide an economic return equivalent to BIP units though a traditional corporate structure. Each BIPC Class A share has same distribution as a BIP unit, and is exchangeable, at the shareholders option, for one BIP unit.

If possible, the investor wishes to minimize the amount of US taxes paid on the dividends. Which should the investor choose — BIP (a master limited partnership), or BIPC (a publicly-traded corporation)?

Assume that the non-resident alien is resident in a tax-free jurisdiction that has no applicable tax treaties with the US.

This document appears to provide the relevant tax information: BIP Taxation Overview – European Investors (although the investor in question is not an EU resident). Apparently, BIP is not a typical US master limited partnership:

Brookfield Infrastructure Partners (“BIP”) is a Bermuda-domiciled limited partnership. BIP does not have the tax characteristics of a typical U.S. Master Limited Partnership (“MLP”), as it does not earn U.S. sourced trade or business income on a flow through basis

Based on my reading of the document, my guess is that the master limited partnership is more favorable for this investor. Reasoning: dividends from BIPC will be taxed at 30%, while only the US-derived portion of the dividends from BIP will be taxed at 30% (2021 Withholding Tax Information for Distributions). I could be wrong about this, so could someone provide an explanation of BIP vs. BIPC from a non-resident alien’s dividend tax perspective?