There are instances outside of securitisations where orphaned SPVs, and the ability to separate "true" owners from "legal" owners, can be used for tax avoidance. For example, restructuring equity into debt, and then relocating this debt to a tax haven via orphaned SPVs, is a classic abuse of orphaning.
In situations beyond securitisations, the application of orphaned Special Purpose Vehicles (SPVs) for separating "true" owners from "legal" ones can aid in tax avoidance. Converting equity into debt and relocating this debt to a tax haven through orphaned SPVs represents an abuse of orphans.