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.
There are instances beyond securitisations where orphaned Special Purpose Vehicles (SPVs) and separating "true" owners from "legal" owners can be employed for tax avoidance. For instance, converting equity into debt and then relocating this debt to a tax haven through orphaned SPVs constitutes a common misuse of orphans.