Featured Commentary Held: The appeal failed. The requirement has relaxed in certain situations such as in the case of Re Coxen (1948) where the inclusion of non-charitable element was allowed as it facilitated the performance of the trusts purpose. The problem of trust failing on this test is largely due to bad drafting. Held: (majority: Lords Watson, Herschell, Macnaghten, and Morris; Halsbury LC and Lord Bramwell dissenting) The deduction should be allowed. He represents the beneficial interest; it follows that in all proceedings in which the beneficial interest has to be before the court, he must be a party. .Cited Lehtimaki and Others v Cooper SC 29-Jul-2020 Charitable Company- Directors Status and Duties A married couple set up a charitable foundation to assist children in developing countries. These can come about when money has been left for a charitable purpose which is not specified, or with no suggestion as to how it should be administered. Basing himself in the Preamble, Lord Macnaghten sought to extract from it a generalised classification of what constitutes charitable in the landmark case Commissioners of Income Tax v Pemsel (1891), which resulted in the following four-fold divisions: Trusts for the relief of poverty Trusts for the advancement of education Trusts for the v. Pemsel.1 Pemsel's Caseis considered to be the major judicial approval of the classification of charitable purposes and charitable objects. The most important feature here is that the Charities Act 2006 removes the presumption, it provides s3(2), the public benefit requirement must be demonstrated in all cases, not just in the first three heads of Lord Macnaghtens classification. Education can also be aesthetics education. .Cited Incorporated Council of Law Reporting For England And Wales v Attorney-General And Others CA 14-Oct-1971 The Council sought charitable status for its activities of reporting the law. The law is absolutely clear on this, however the inconsistencies have occurred in the application of the law. .Cited Gilmour v Coats HL 1949 Prayers Alone did not make Convent Charitable A trust to apply the income of a fund for all or any of the purposes of a community of Roman Catholic Carmelite nuns living in seclusion and spending their lives in prayer, contemplation and penance, was not charitable because it could not be shown . [16], The "poverty" category is a "major exception" to the rule on personal relationships laid down in Oppenheim v Tobacco Securities Trust. These vary depending on whether the gift that creates the trust is given in life, given after death, or includes land. A Notice of Reference dated 27 January 2011 was made by Her Majesty's Attorney General following concerns expressed by the Charity Commission that the Charities Act 2006 (2006 Act) had cast doubt on the continued charitable status of certain charitable trusts. The Act also excludes private clubs, unless the members fall under Section 1(2)(a). "Education" also includes research, as long as the subject is useful and the gift makes some requirement that the information be made available to others and disseminated. If the money is to be spent on non-charitable purposes, the trust fails, regardless of the fact that it applies to a particular area. (v) Defined contribution plans subject to the funding standards. .if(typeof ez_ad_units != 'undefined'){ez_ad_units.push([[300,250],'swarb_co_uk-medrectangle-4','ezslot_8',113,'0','0'])};__ez_fad_position('div-gpt-ad-swarb_co_uk-medrectangle-4-0'); Lists of cited by and citing cases may be incomplete. 1 Income Tax Special Purpose Commissioners v Pemsel [1891] AC 531. Court approval was . In order to determine the purposes are charitable, the courts have decided that the purposes should fall within the objects set out in Preamble to the Charitable Uses Act 1601. The doctrine originated in ecclesiastical law, the name coming as a contraction of the Norman French cy pres comme possible (as close as possible),[71] and is typically used where the original purpose of the charity has failed, and results in the trust purpose being altered to the nearest realistic alternative. [68] Schemes may also be used to fix administrative difficulties caused by uncertainty, as in Re Gott,[69] or even to completely defeat the gift. [3] Charitable trusts are also exempt from many formalities when being created, including the rule against perpetuities. In this Equity Short, Dr John Picton discusses the legacy of Special Commissioners of Income Tax v Pemsel [1891] A C 531. An organisation whose aims . The courts are increasingly setting out the underlying principles when deciding cases on charitable . . Commissioners of Special Purposes of Income Tax v Pemsel Lord MacNagthen classified the recognized purposes of charitable trust into four heads: i) relief of poverty ii) advancement of education iii) advancement of religion iv) other purposes beneficial to the communities . d. Trust for other purposes beneficial to the community not falling under the previous three head.-PUBLIC BENEFIT Verge v Somerville [1924] AC . [59], The administration of charitable trusts is covered primarily by the Charities Act 1993 and the Charities Act 2006, and is widely divided between four groups; the Attorney General for England and Wales, the trustees, the Charity Commission and the Official Custodian for Charities.[60]. make a difference between campaigning and political activity. Registered office: Creative Tower, Fujairah, PO Box 4422, UAE. View examples of our professional work here. The company should have . [32] Curiously, and individually to religious charities, the public benefit requirement is justified by the assumption that, according to Cross J in Neville Estates v Madden,[33] "some benefit accrues to the public from attendance at places of worship of persons who live in this world and mix with their fellow citizens". If the gift was charitable, the gift would be applied cy pres, but if not it would fail and pass to the family and be subect to Inheritance Tax. Secondly the purpose must be for the benefit of the public at large or a section of the public at large and thirdly the purpose must be exclusively charitable. .Explained In re Macduff; Macduff v Macduff CA 1896 Lindley LJ qualified the judgment of Lord Macnaghten in Pemsel: Now Sir Samuel Romilly did not mean, and I am certain Lord Macnaghten did not mean, to say that every object of public general utility must necessarily be a charity. . Before making any decision, you must read the full case report and take professional advice as appropriate. The defendants (H) were the owners of a hotel. It has been argued that there has been a weakening in the courts attitude to purportedly charitable trusts recently. When the marriage failed an attempt was made to establish a second foundation with funds from the first, as part of W leaving the Trust. Charities for the purpose of creating animal sanctuaries usually pass the public benefit test despite this, because they do not completely exclude the public and often have educational value. Wood, Richard J, 'Pious Politics: Political Speech Funded Through IRC 501(c)(3) Organizations Examined Under Tax Fairness Principles' (2007) 39 Arizona State Law Journal 209. . Income Tax Special Purposes Commissioners v Pemsel [1891] AC 531 In this case, Lord Macnaughten classified charitable purposes under four heads: the relief of poverty; the advancement of education; the advancement of religion; and other purposes beneficial to the community not falling under any of the preceding heads. [57] The Census of 1861 recorded his occupation as a Commercial Clerk, at Manchester Shipping House. Peggs v Lamb [1994] 2 WLR 1. The Revenue appealed against the decision by Foster J that the Council ought to be registered as a charity. The plaintiff (B) was a brewer. Case law Income Tax Commissioners v Pemsel [1891] Gilmour v Coats McGovern v A-G [1982] Oppenheim v Tobacco Securities Trust Co Ltd [1950] National Anti-Vivisection Society v IRC [1947] Dingle v Turner [1972] Independent Schools Council v Charity Commission [2011] A-G v Charity Commission for England and Wales [2012] . The exempt purposes set forth in Internal Revenue Code section 501(c)(3) are charitable, religious, educational, scientific, literary, testing for public safety, fostering national or international amateur sports competition, and the prevention of cruelty to children or animals. The point here is as Lord Cross suggested is that there must be some genuine charitable intention on the part of the settlor. This means that trusts for the relief of poverty can be valid, even if only a few people will benefit from the trust; as long as there was a genuine intention to relieve poverty. Currently governed by and exercising its functions under the Charities Act 2011, it has five core objectives: Along with these objectives, it has six functions under the 2011 Act: The Charity Commission has the power to issue an inquiry into a charity under Section 46 of the 2011 act and, if they are satisfied there has been mismanagement, they are allowed to suspend trustees or officers, appoint additional trustees, vest charity property in the Official Custodian for Charities or order debtors or people holding charity property not to transfer it without their permission. The use of other words such as "beneficial" or "benevolent" causes the trust to fail at creation, as the words are not synonymous with charity. Section 1(1) of the Act, however, preserves the need to provide a "public benefit". It provides for situations where political activity can be carried out, in order to support the delivery of its charitable purposes. 39. The trusts last referred to are not the less charitable in the eye of the law, because incidentally they benefit the rich as well as the poor, as indeed, every charity that deserves the name must do either directly or indirectly.Lord MacNaghten contrasted the systems of administrative law in England and Scotland: By expounding the Act by analogy, and if you will apply your usual penetration to this point, you will find that there is often no other possible way of making a consistent sensible construction upon statutes conceived in general words, which are to have their operation upon the respective laws of two countries, the rules and forms whereof are different. [23], For artistic pursuits, it is not enough to promote such things generally, as it is too vague. Statutes . [2], There are a variety of advantages to charity status. [51] This line is considered by the Charity Commission in their official guidelines, which allow the Commission to look at the wider purpose of the organisation when deciding if it constitutes a valid charity. Without the values and principles which underlie not only the Charter but also our democratic institutions and policy . LORD HALSBURY L.C. The House defined what is meant at law by a charity. swarb.co.uk is published by David Swarbrick of 10 Halifax Road, Brighouse, West Yorkshire, HD6 2AG. It seems to me that there is much good sense in what Lord Hardwicke said in his well known letter to an eminent Scottish judge you must he says as in other sciences reason by analogy that is, as I understand it, you must take the meaning of legal expressions from the law of the country to which they properly belong, and in any case arising in the sister country you must apply the statute in an analogous or corresponding sense so as to make the operation and effect of the statute the same in both countries. Cited - Incorporated Council of Law Reporting For England And Wales v Attorney-General And Others CA 14-Oct-1971. An organisation whose aims could be seen as harmful to the public could not be recognised as a charity. The scheme may be used to appoint new trustees, except when the trustee's identity is crucial to the intentions of the testator, as in Re Lysaght. Again, this excludes trusts which isolate the beneficiaries from the public, as in Re Grove-Grady,[38] where the trust sought to provide "a refuge [for animals] so that they shall be safe from molestation and destruction by man". the statute proclaims its origin and speaks the language of the English lawyer, with some Scottish legal phrases thrown in rather casually. .Cited Guild v Inland Revenue Commissioners HL 6-May-1992 The will left land for a sports centre to a local authority which no longer existed. Trust instruments should ideally identify that the money is to be used for "charitable purposes". However there is no clear line that the law draws here and thus inconsistencies have occurred. IRC v Oldham Training & Enterprise Council [1996] STC 1218. trust to set up unemployed in trade or business & enable them to stand on their own feet held to be charitable for the relief of poverty ; . These general views will probably always be taken from the language or style of one of these countries more than from the other, and not correspond equally with the genius or terms of both laws. it had already been recognised that a trust for the relief of poverty amongst a testator's relatives was charitable: Isaac v Defriez (1754) Amb 595; whereas a trust for the advancement of education of a testator's relatives was not. Charitable trusts in English law are a form of express trust dedicated to charitable goals. [1] If the gift is of personal property and made inter vivos, there are no formal requirements; it is enough that an oral declaration is made creating the trust. The classification is to be used for a matter of convenience and is not a definition. The case arose from a decision of the Inland Revenue Commissioners to restrict the types of An example is the Privy Council decision in Attorney General of the Cayman Islands v Wahr-Hansen,[54] where the Council held that gifts to "organisations or institutions operating for the public good" and acting "for the good or for the benefit of mankind" failed, because the definition given was not exclusively charitable.[55]. [65], The jurisdiction of the Charity Commission is concurrent with that of the High Court of Justice. Schemes can also be used, on the application of trustees, to extend powers of investment or consolidate funds. IRC v Pemsel Charitable purposes fall into only four categories: relief of poverty, advancement of education, advancement of religion, other purposes beneficial to the community. [30] This category also covers groups with small followings, as in Re Watson,[31] and with doubtful theology, as in Thornton v Howe. How are you to approach the construction of such statutes? There are two exceptions to the rule of exclusivity; ancillary purposes, and severance. There is no statutory definition of what a charity is; it is instead dealt with in a roundabout way. There is also room for organisations to get charitable status even if campaigning is a major part of their work if it is set out appropriately in the governing document e.g. Section 2(2) (b) is the advancement of education which may be suitable for Lauras second gift. The public benefit was central to the validity of trusts which fell into the fourth category in Verge v Somerville (1924) the charitable statues of trusts depend on whether the benefit which they provide are available to the community at large. To be a valid charitable trust, the organisation must demonstrate both a charitable purpose and a public benefit. Cited Inland Revenue Commissioners v Glasgow Police Athletic Association HL 9-Mar-1953 The House was asked whether the taxpayer association was established for Charitable purposes only so as to benefit from tax exemptions. Academics Richard Edwards and Nigel Stockwell argue that this is because allowing such trusts to exist relieves the rest of society for having to provide for poor people; as a result, there is "public benefit" in a wider way. The main object of the Society was political viz, the repeal of the Cruelty to Animals Act 1876, and for that reason the Society was not established for charitable purposes only and was not entitled to exemption from tax. Hence it would appear that the degree of, between the two purposes have to be looked at. The issue occurred again in the case of McGovern v Att-Gen 1982 where Amnesty International sought to seek charitable status for part of its organisation. While the beneficiaries were all linked by a personal relationship (their employer), the courts ruled that poverty is an exception to the Oppenheim rule. Pemsel case Poverty Re Coulthurst Re Sanders' Will Trust Re Niyazi's Will Trust Dingle v Turner Re Segelman Attorney General v Charity Commission for England and Wales Education IRC v McMullen McGovern v AG Re Shaw The Independent Schools Council v The Charity Commission Religion Gilmour v Coates Health Re Resch's Will Trust . Two approaches towards the validity of charitable purpose have arisen. Rather, the beneficiaries are represented by the Attorney General for England and Wales as a parens patriae, who appears on the part of The Crown. Disclaimer: This essay has been written by a law student and not by our expert law writers. [50] There is a dividing line; charitable trusts discussing political issues can be valid, as discussed by Hoffmann J obiter dicta in Attorney General v Ross. The general principle is that political trusts are not charitable and this position has not been affected by the Charities Act 2006. [10], Trusts must also be for "public benefit", which was considered at length in Oppenheim v Tobacco Securities Trust. This definition was expanded on by Slade J in McGovern v Attorney General, where he said that: (1) A trust for research will ordinarily qualify as a charitable trust if, but only if (a) the subject matter of the proposed research is a useful object of study; and (b) if it is contemplated that the knowledge acquired as a result of the research will be disseminated to others; and (c) the trust is for the benefit of the public, or a sufficiently important section of the public. That gifts to be charitable were traditionally classified into four categories known as Pemsel categories, namely: the relief of poverty, the advancement of education, the advancement of religion, and other purposes beneficial to the community: whereas there is a presumption that the first three categories are for the public benefit, such Blair v Duncan (1902), Re Sutton (1885) etc. The Commission is also authorised to appoint new trustees to replace removed ones, or even to increase the number of trustees. Facts. [28], For the purposes of this category, "religion" was seen to mean a faith in a higher power, and does not include ethical principles or rationalism, as in Bowman v Secular Society. Also at the same time cases such as Baldry v Feintuck (1972), AG v Ross (1986) have held that bodies that are considered to be charitable in educational circle will be precluded from engaging in political activities or supporting political causes. This results in two things; firstly, the trustees of a charitable trust are far freer to act than other trustees and secondly, beneficiaries cannot bring a court case against the trustees. (B) Profit-sharing plan of affiliated group. Another situation is where the non-charitable element is merely incidental to the main chariatable purpose e.g. Free resources to assist you with your legal studies! We and our partners share information on your use of this website to help improve your experience. The Commission, the first port of call, is tasked with regulating and promoting charitable trusts, as well as providing advice and opinions to trustees on administrative matters. The first approach is that the applicant show a general charitable purpose e.g. In addition, it is considered unacceptable for charitable trusts to campaign for political or legal change, although discussing political issues in a neutral manner is acceptable. And yet of all words in the English language bearing a popular as well as a legal signification I am not sure that there is one which more unmistakably has a technical meaning in the strictest sense of the term, that is a meaning clear and distinct, peculiar to the law as understood and administered in this country, and not depending upon or coterminous with the popular or vulgar use of the word. Lord Macnaghten, Lord Watson, Lord Morris, Lord Herschell [1891] AC 531, [1891] UKHL 1, [1891] UKHL TC 3 53, (1891) 3 TC 53 Bailii, Bailii Statute of Charitable Uses 1601 Scotland Cited by: Cited Reclaiming Motion In Petition of Scott Davidson for Judicial Review of A Decision To Continue To Detain the Prisoner In Inhuman and Degrading Prison C SCS 18-Dec-2001 A prisoner sought an order for his removal from a prison found to have a regime which breached his human rights. The definitions of a trustee and a trust within charitable trusts differ significantly from the norm. Any case involving charities has him joined as a party, he may act against trustees in disputes, and take actions to recover property from third parties. [62] They can also remove trustees on the grounds of bankruptcy, mental incapacity, failure to act or the trustee's absence from the country. The Revenue appealed against the decision by Foster J that the Council ought to be registered as a charity. National Anti-Vivisection Society v IRC (BAILII: [1947] UKHL 4) [1948] AC 31 ; Nelson v Nelson (1995) 184 CLR 538 (Australia) Nestle v National Westminster Bank (BAILII: [1992] EWCA Civ 12) [1993] 1 WLR 1260, [1994] 1 All ER 118 ; Neville Estates v Madden [1962] Ch 832 ; Neville Estates v Madden[1962] Ch 832 (ICLR) At the same time it has never been forgotten that the objects there enumerated, as Lord Chancellor Cranworth observes, are not to be taken as the only objects of charity but are given as instances. and I have dwelt for a moment on this point, because it seems to me that there is a disposition to treat the technical meaning of the term charity rather as the idiom of a particular Court than as the language of the law of England. As a result, the trust failed. As mentioned, charitable trustees have significantly more freedom to act than normal trustees, but the 1993 Act has put restrictions on who may be a charitable trustee. If the subject is useful subject of research and it intends to publish the results of that research it will be allowed. Lord McNaghten. However the head does consider a wide range of activities as said in the case of McGovern v AG 1982 contribute to the improvement of a useful branch of human knowledge and its public dissemination. The leading case of McGovern v AG (1982) sets out the principles on which a court will typically find research work to be charitable. The standard categorisation (since all previous attempts to put it on the statute books were "unduly cumbersome") was set out by Lord Macnaghten in IRC v Pemsel,[9] where he said that "Charity in its legal sense comprises four principal divisions: Trusts for the relief of poverty; trusts for the advancement of education; trusts for the advancement of religion; and trusts for other purposes beneficial to the community". [8], The first definition of a "charitable purpose" was found in the preamble to the Charitable Uses Act 1601. However in, the first gift the courts may feel that the unemployed may not be a large section of the public as this depends on the economy of the country. Thus you get what Lord Hardwicke calls consistent, sensible construction.Lord Macnaghten discussed the development of the law of charity, saying of the 1601 Statute: The object of that statute was merely to provide new machinery for the reformation of abuses in regard to charities. 1) IRC v Pemsel [1891] AC 531, Lord MacNaghten classified the trusts which have been held to be charitable under four heads which are. The Council sought charitable status for its activities of reporting the law. Industrial Development Consultants v Cooley; IRC v Baddeley; IRC v Bernstein; IRC v Broadway Cottages Trust; IRC v McMullen (J) Jaffa v The Taylor Gallery; Jaggard v Sawyer, James, Re; James v Thomas; JD Wetherspoon plc v Van de . The other problem is that it may be seen as a class within a class as in case of IRC v Baddeley (1955). This article questions whether in the area of poor relief equity acts out of a humanitarian regard for those whose relief is the purpose of the trust, or whether there is a more . Determining whether institutions are or are not charities. The first definition of a "charitable purpose" was found in the preamble to the Charitable Uses Act 1601.The standard categorisation (since all previous attempts to put it on the statute books were "unduly cumbersome") was set out by Lord Macnaghten in IRC v Pemsel, where he said that "Charity in its legal sense comprises four principal divisions: Trusts for the relief of poverty; trusts for . In IRC v Baddeley (1955) it was held that a trust which provided outlet for members would be members of the Methodist church, in West Ham; was not charitable since this was not a section of the community but a class within a class. N.B. .Cited Davidson v Scottish Ministers HL 15-Dec-2005 The complainant a prisoner sought an order that he should not be kept in conditions found to be inhumane. J and P M Dockeray (A Firm) v Secretary of State for the Environment, Food and Rural Affairs: Admn 18 Mar 2002, EB (Kosovo) v Secretary of State for the Home Department: HL 25 Jun 2008, Income Tax Special Commissioners v Pemsel, British Airways Plc v British Airline Pilots Association: QBD 23 Jul 2019, Wright v Troy Lucas (A Firm) and Another: QBD 15 Mar 2019, Hayes v Revenue and Customs (Income Tax Loan Interest Relief Disallowed): FTTTx 23 Jun 2020, Ashbolt and Another v Revenue and Customs and Another: Admn 18 Jun 2020, Indian Deluxe Ltd v Revenue and Customs (Income Tax/Corporation Tax : Other): FTTTx 5 Jun 2020, Productivity-Quality Systems Inc v Cybermetrics Corporation and Another: QBD 27 Sep 2019, Thitchener and Another v Vantage Capital Markets Llp: QBD 21 Jun 2019, McCarthy v Revenue and Customs (High Income Child Benefit Charge Penalty): FTTTx 8 Apr 2020, HU206722018 and HU196862018: AIT 17 Mar 2020, Parker v Chief Constable of the Hampshire Constabulary: CA 25 Jun 1999, Christofi v Barclays Bank Plc: CA 28 Jun 1999, Demite Limited v Protec Health Limited; Dayman and Gilbert: CA 24 Jun 1999, Demirkaya v Secretary of State for Home Department: CA 23 Jun 1999, Aravco Ltd and Others, Regina (on the application of) v Airport Co-Ordination Ltd: CA 23 Jun 1999, Manchester City Council v Ingram: CA 25 Jun 1999, London Underground Limited v Noel: CA 29 Jun 1999, Shanley v Mersey Docks and Harbour Company General Vargos Shipping Inc: CA 28 Jun 1999, Warsame and Warsame v London Borough of Hounslow: CA 25 Jun 1999, Millington v Secretary of State for Environment Transport and Regions v Shrewsbury and Atcham Borough Council: CA 25 Jun 1999, Chilton v Surrey County Council and Foakes (T/A R F Mechanical Services): CA 24 Jun 1999, Oliver v Calderdale Metropolitan Borough Council: CA 23 Jun 1999, Regina v Her Majestys Coroner for Northumberland ex parte Jacobs: CA 22 Jun 1999, Sheriff v Klyne Tugs (Lowestoft) Ltd: CA 24 Jun 1999, Starke and another (Executors of Brown decd) v Inland Revenue Commissioners: CA 23 May 1995, South and District Finance Plc v Barnes Etc: CA 15 May 1995, Gan Insurance Company Limited and Another v Tai Ping Insurance Company Limited: CA 28 May 1999, Thorn EMI Plc v Customs and Excise Commissioners: CA 5 Jun 1995, London Borough of Bromley v Morritt: CA 21 Jun 1999, Kuwait Oil Tanker Company Sak; Sitka Shipping Incorporated v Al Bader;Qabazard; Stafford and H Clarkson and Company Limited; Mccoy; Kuwait Petroleum Corporation and Others: CA 28 May 1999, Worby, Worby and Worby v Rosser: CA 28 May 1999, Bajwa v British Airways plc; Whitehouse v Smith; Wilson v Mid Glamorgan Council and Sheppard: CA 28 May 1999. The Charities Act 2006 states in section 1(1) that: For the purposes of the law of England and Wales, 'charity' means an institution which (a) is established for charitable purposes only, and (b) falls to be subject to the control of the High Court in the exercise of its jurisdiction with respect to charities. the object of repealing the Act of 1876 was a main object, if not the main object, of the Society, to obtain an alteration of the law. Seeking an amendment of acts of parliament, or even their repeal, where that is ancillary to one of the established charitable objects in common law did not deprive an organisation of its charitable status. For a discussion of the different shades of meanings in these terms, see Hkon . The Political Activities and Campaigning by Charities (2004) states a charitable may engage in political activity where to do so will enhance or facilitate or support its work.. Although wide, this excludes things that the courts feel are harmful; in Re Shaw,[21] Harman J excluded schools for pickpockets or prostitutes. This appears to indicate that a millionaire who loses half of his income may be considered "poor", in that he is unable to have the lifestyle he is accustomed to. See also Lords Bramwell and Macnaghten in Commissioners for Special Purposes of Income Tax v Pemsel (hereafter Pemsel) (1891) AC 53 1 at 566 and 591; and Radcliffe Commission Final Report on Taxation of Profits and Income (Cmnd 9474) (1955). Notably, this excludes gifts to groups which do not associate with the public, as in Gilmour v Coats. They are free from the income tax paid by individuals and companies, and also the corporation tax paid by incorporated and unincorporated associations. The guiding principles in such cases are as follows: where connecting word is or this is construed disjunctively which means the trust is not to be regarded as exclusively charitable e.g.
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