Question
34. D transferred $10,000,000 cash to an irrevocable trust in Year I.D's three children (A, Band C) were trust beneficiaries. Each of A, Band C
34. D transferred $10,000,000 cash to an irrevocable trust in Year I.D's three children (A, Band C) were trust beneficiaries. Each of A, Band C were entitled to an equal share of trust income and in addition, the Trustee(s) had the discretionary power to distribute trust principal in their discretion. D and A were co-trustee ' s, any decision made by them required to be unanimous (they had to agree).In Year 2, A and D (as Trustee's) agreed to distribute $10,000 to A. In Year 5, A and D agreed to distribute $50,000 to B. In Year 15 A and D agreed to distribute $100,000 to C. ln Year 18 A died. In Year 20 D died when the FMV of the Trust was $11,000,000. (Assume D makes no other transfers, ever, and applies the annual exclusion to any completed gift IF allowed).
a. Has D made any taxable gifts?Ifso how much and when?
b. How much, if anything, is included in D's Gross Estate?
c. How much, if anything, is included in A's Gross Estate?
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