Where an ethnic religious community is established as an unincorporated association with rules referencing a hierarchical church, the trust will ordinarily be construed as a trust for the purposes of that hierarchical church, subject to the constitution and discipline of the wider church body. However, significant congregational involvement prescribed by the founding rules may form part of the trust terms, qualifying the hierarchy's absolute control. Anti-communist or political provisions in founding rules of a 1950s migrant community are incidental regulations, not core terms of the trust. A trust for an unincorporated association that prevents members from ever dividing property beneficially will fail for perpetuity unless it qualifies as charitable. Where rules of an unincorporated association contain no provision for amendment, a unanimous resolution of all members is required for fundamental alteration.
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