In Commissioners for Special Purposes of Income Tax v. Pemsel (1891), Lord McNaughten identified four categories of charity which could be extracted from the Charitable Uses Act and which were the accepted definition of charity prior to the Charities Act 2006: the relief of poverty, the advancement of education, the advancement of religion, and other purposes considered beneficial to the community. Charities in England and Wales – such as Age UK, the Royal Society for the Protection of Birds (RSPB) and the Royal Society for the Prevention of Cruelty to Animals (RSPCA) – must comply with the 2011 Act regulating matters such as charity reports and accounts and fundraising. Structures , there are a number of types of legal structure for a charity in England and Wales: Unincorporated association Trust Company limited by guarantee Another incorporation, such as by royal charter Charitable incorporated organization The unincorporated association is the most common form of organization within the voluntary sector in England and Wales. This is essentially a contractual arrangement between individuals who have agreed to come together to form an organization for a particular purpose. An unincorporated association will normally have as its governing document a constitution or set of rules, which will deal with such matters as the appointment of office bearers, and the rules governing membership. The organization is not though a separate legal entity, so it cannot start legal action, it cannot borrow money, and it cannot enter into contracts in its own name. Its officers can be personally liable if the charity is sued or has debts. A trust is essentially a relationship among three parties: the donor of some assets, the trustees who hold the assets, and the beneficiaries (those people who are eligible to benefit from the charity). When the trust has charitable purposes, and is a charity, the trust is known as a charitable trust. The governing document is the trust deed or declaration of trust, which comes into operation once it is signed by all the trustees. The main disadvantage of a trust is that, as with an unincorporated association, it does not have a separate legal entity and the trustees must themselves own property and enter into contracts. The trustees are also liable if the charity is sued or incurs liability. A company limited by guarantee is a private limited company where the liability of members is limited. A guarantee company does