In the case of Commissioner for Special Purposes of Income Tax v. Pensel, Lord MacNaughten divided this trust into four major headings;

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  1. Trust for relief of property
  2. Trust for the advancement of education
  3. Trust for advancement of religion
  4. Trust for other purposes beneficial to the community



1. For the relief of poverty:

This class is exempted from the public benefit test and was originally used to provide for the “aged, impotent and poor”.

2. For the advancement of education:

This focuses on the promotion of education for the general good

3. For the Advancement of religion:

This refers to the promotion of spiritual teaching and the maintenance of the doctrines on which it rests

4. For purposes beneficial to the community:

This focuses on all things not under the prior three and extends from trusts for sports and recreation to trusts for the welfare of animals

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