(Discovered by @RickBrice) - The Validation Service (v0.8.4) does not flag an issue with IfcFaceOuterBound.Orientation when used to describe an IfcClosedShell. Specifically, the Orientation attribute is used to indicate if the sense of the face normal is the same or opposite of the solid normal (pointing from finite to infinite).
A sample model exists; however it cannot be shared publicly at this time.