Where a person purports to alienate a right to income in favour of another person, the alienation, to be effective, must operate to divest immediately the alienor's beneficial interest and vest it in the recipient. This may be effected by a valid and effective transfer by the owner of the right to income, or by the declaration of a valid trust of the income in favour of a beneficiary. A trust cannot be created by an incomplete transfer, but can be created by a complete and unequivocal declaration of trust
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