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A gifts $ 1 0 0 , 0 0 0 to a trust for the benefit of A s grandchild, GC . GC has the

A gifts $100,000 to a trust for the benefit of As grandchild, GC. GC has the right to withdraw up to $17,000 from the trust each year, and A makes no other gifts to GC during the year. The trust has to be paid out to GC during his life, or is includable in GCs estate at GCs death. A has $1M of gift tax exemption remaining, but no GST exemption remaining at the time of the gift. How much of the gift is subject to GST tax?

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