 In Re Finger , Goff J made a distinction between gifts to incorporated bodies and gifts to unincorporated bodies . When a gift is to an unincorporated body , it must be treated , whatever the wording , as a gift to that body 's purpose . This is because unincorporated bodies cannot possess things . If the body has ceased to exist but the purpose continues , the gift has not failed . Incorporated bodies on the other hand can possess property , and as such , as said by Buckley J in Re Vernon 's Will Trust , " A bequest to a corporate body ... takes effect simply as a gift to that body <unk> , unless there are circumstances which show that the recipient is to take the gift as a trustee . " 
