RE:RE:RE:RE:RE:RE:OrderGRZ has been aware of the award taxation issue for many years and they've had top experts get them totally on top of it. I recall discussing the matter with Doug maybe 5 years ago. From the reference in the GRZ press release to double taxation it sounds like the US and Canada both want a full tax bite at this.
Not a surprise at all. Why wouldn't they both want a full tax bite? And may be that this IRS approach IS on point with regard to the other (US-based) entities going after CITGO.
I'm pretty sure the key thing here is that GRZ is, technically, a Canadian company. Incorporated in Alberta. Previously the Yukon. Doesn't matter that their HQ is in the US. Or that they are in US court.
GRZ will prevail vs. the IRS.
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Now that I think about it, I recall that the question of where GRZ is incorporated came up in the ICSID arbitration so long ago. I think the Venezuelans tried to argue that the Canadian incorporation was just a smokescreen and it was REALLY a US company. Argument didn't work.
GRZ knows all this stuff backwards and forwards.