Accumulation may be implied from the form or nature of a gift, where the substantial meaning of the limitation requires that accumulation is to take place, or where accumulation would be the inevitable result of the limitation either generally or upon certain contingencies1. This is a question of construction, determined as if no statutory provisions restricting accumulation existed2.
It seems that there is an implied trust to accumulate where surplus income of a fund, accruing after the expiration of the statutory period3, is directed to be added to the capital of settled residue, and the direction fails accordingly4.
A trust for
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