Based on the guidance contained in the textbook and IRC, a gift occurs when the transfer of property is complete and the gift is valued at the date of the transfer. Imagine a scenario in which a client creates an irrevocable trust for his two (2) grandchildren to attend college. Discuss the tax issues or consequences of the generation skipping provision, and a direct gift to the grandchildren instead of creating the trust. Make at least two (2) recommendations as to how the client could minimize the tax consequences of the gift.