02:45 PM EST, 11/26/2024 (MT Newswires) -- Gold Reserve ( GDRZF ) was at last look on Tuesday down near 30% and touched near 52 week lows after saying it received a letter from the Canada Revenue Agency advising that, subject to submissions by the company, the CRA proposes to reassess it.

According to a statement the CRA will reassess to include in its income certain amounts, including amounts in respect of the September 2014 arbitral award and/or the company's settlement agreement with Bolivarian Republic of Venezuela. As previously disclosed, the company has been under examination by the CRA in excess of three years. The CRA's proposal letter was received subsequent to the company's continuance from Alberta, Canada to Bermuda.

Tuesday's statement noted the proposal letter consists of multiple alternative bases of assessment, in respect of the 2014, 2016, 2017 and 2018 taxation years of the company. The maximum potential income inclusion amounts as set out in the letter are the full amount of the award of US$740.3 million, the sales proceeds of the mining data related to the Brisas Project of US$240 million, a C$50.1 million 2017 shareholder benefit and a C$163.2 million 2018 shareholder benefit (exclusive of interest and any penalties).

However, the statement said, these amounts do not take into account any deductions or adjustments that may be available to the company to reduce the amount of the proposed income inclusions. In the approximately 10 years since the award was granted, the company has received approximately $14 million pursuant to the award. The company's U.S. subsidiary received US$240 million related to the mining data and reported such amount as taxable income. The company added: "At this time, given the multiple alternative bases of assessment proposed, we are unable to estimate the potential tax impact but are working diligently along with our advisors to do so. The matter is highly uncertain, particularly given the unusual nature of the proposed alternative assessments." GRZ noted the CRA has delayed reassessment of the above proposed audit adjustments to January 31, 2025 to provide the company an opportunity to respond to the proposal letter.

The company is preparing to defend its previous tax filing positions and assessing the potential outcomes of this matter.

Price: 1.80, Change: -0.87, Percent Change: -32.58