The purposes of the appellant were not exclusively charitable because they included not only education of immigrant women but also doing that which was "conducive" to the attainment of such objects (which was a broader term than "incidental").
After noting (at p. 5043) that the educational charitable head should not be restricted to the "formal training of the mind" and that any knowledge or training that "is provided in a structured manner and for a genuinely educational purpose - that is, to advance the knowledge or abilities of the recipient - and not solely to promote a particular point of view or political orientation" would qualify, he went on to note that the intended purposes (and the actual activities that were carried out) were not restricted to such matters as training the beneficiaries how to apply for a job but also extended to establishing a job skills directory, networking, liaising for accreditation of credentials, soliciting job opportunities and offering referral services. These were not educational, and did not fall under the fourth head.