A gifts $100,000 to a trust for the benefit of A's 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 GC's estate at GC's 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?