benefit of persons, or charitable purposes, many offshore jurisdictions have also amended their laws to permit trusts to be formed for non-charitable purposes. Such trusts need to enforce a "protector" to be able to enforce the terms of the trust, but doubt remains as to who should be treated as the beneficial owner of the trust funds for tax purposes prior to its distribution. No offshore jurisdiction yet appears to have made a serious effort to expand upon the flexibility of discretionary trusts in relation to certainty of objects, as expounded in McPhail v Doulton. This may be because the common law rules are now considered to be sufficiently flexible to make no widening necessary to attract trust business. Anachronistic common law rules Many offshore jurisdictions have also legislated to abolish certain anachronistic common law rules which sometimes cause difficulty for trust planning. These include: Rule in Howe v Earl of Dartmouth Rule in Maloney v Alveranga Rule in Re Atkinson See also Private foundation References Equity (law) Wills and trusts Offshore finance Legal entities