<P> A sum of money, say 10,000, does not satisfy the requirement, rendering uncertainty . </P> <P> This is part of the "orthodox" or "strict" rule, along with Re Goldcorp . The exception to this rule is found in Hunter v Moss, which concerned 50 shares meant to be transferred to an employee out of a total holding of 950 . These shares were not individually identified, but Dillon LJ held that this was irrelevant because the shares were all of the same type and in the same company, and so it made no difference which particular shares were transferred . This was applied in Re Harvard Securities, where Neuberger J held that there was a difference between tangible property, such as wine, and intangible property, such as shares . Intangible property, by its very nature, does not require segregation . A failure in the formality of this head would lead to the property being result back to the estate on resulting trust . </P> <P> There is a requirement that the beneficiaries of a trust, known as the objects, be certain . Within express trusts this is a particularly complex area, because the test used to determine certainty varies between fixed trusts, mere powers and discretionary trusts . Fixed trusts are trusts for a specific, named list of individuals, with Alastair Hudson giving the example of "£ 10,000 to be held upon trust equally for the complete team of 11 Sunderland Football Club players who started the 1992 Cup Final at Wembley". The test for fixed trusts is that the trustees must be able to give a complete list of the beneficiaries, as laid down in IRC v Broadway Cottages . If there are any potential beneficiaries who the trustees are not certain of, or the trustees cannot compile a complete list, the trust is void for uncertainty . </P> <P> A more complex test is found with mere powers . These are where a person is granted the power (the ability) to exercise a trust - like power, but without any obligation to do so, such as "the trustee may give £ 1,000 to X", or "the trustee can, at his discretion, give £ 1,000 to X" as opposed to "the trustee shall give £ 1,000 to X". In Re Hay's ST, Megarry VC said that: </P>

Inland revenue commissioners v broadway cottages trust 1955 ch 20
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