In December 2009, individual taxpayers participated in a tax shelter that involved making both a leveraged investment (the "LP Program") and leveraged donation. In the lP Program, they used money borrowed from a lender trust (FT) (the "Unit Loans") to purchase units in an Ontario LP, which used most of the proceeds to purchase notes of a BVI company (Leeward). The return on the notes was linked to whichever of a stock market index and a notional balanced portfolio performed the better, with Leeward then lending the funds back to FT via a second trust.
