Under the common law rule what about a grant "to General Motors Corporation and its successors and assigns in Fee Simple Absolute."
What is the state of the title? Since corporations have no heirs, the common law did not require the magic words to create a fee simple in a corporation. General Motors has a Fee Simple Absolute under the common law rule. As Moynihan put it, under the common law "because a corporation can have no heirs, a conveyance to a corporation gave it a fee simple absent some expression of contrary intent."
So "to GM forever," or "to GM and its assigns forever," or even, presumably, merely "to GM" would create a Fee Simple Absolute in GM.
