 Similarly, if the trusts are held for a tenant for life, and then for the benefit of a remainderman, both tenant for life and remainderman may decide to terminate the trusts and obtain the capital immediately, and agree a partition of the funds between them; this situation often occurs where changes in the revenue laws means that upon the death of the tenant for life the trust fund may be subject to inheritance tax in a way that was not envisaged when the trust fund was originally set up.It has also been held that the rule in "Saunders v Vautier" also applies to discretionary trusts as well as fixed trusts.However, some caution is in order, as that decision was made at a time when the law was understood to require that a valid discretionary trust need to be able to draw up a complete list of the beneficiaries of the trust in order to be valid; subsequent to the decision of the House of Lords in "McPhail v Doulton" [1971] AC 424, this is no longer the appropriate test, and accordingly it may be that not all discretionary trusts are capable of being terminated by the beneficiaries under the rule.