The government had argued that the partnership's sole purpose was the avoidance of taxes-- one mark of an abusive tax shelter, in the judgment of the IRS . The agency had also argued that the Dutch banks were lenders to, not partners of, Castle Harbour, since GE Capital had prohibited them from selling their interests.
12.
Mauritius and Singapore with their small economies cannot be the sources of such huge investments and it is apparent that the investments are routed through these jurisdictions for avoidance of taxes and for concealing the identities from the revenue authorities of the ultimate investors, many of whom could actually be Indian residents, who have invested in their own companies.
