“…Kieninger in particular has for many years put pressure on this submission. 114 Von Bar and Drobnig, in their study of property law and how it relates to contract law, offer evidence that foreign companies may be hesitant to trade with Dutch companies because of the existence of the right of seizure of the Tax authority. 115 A fact pattern concerning the recognition of a foreign property right and the following transformation of that right into a national law equivalent should therefore be considered much less 'unusual' than is usually suggested.…”