Brad, your 87 year old client, establishes The Brad Irrevocable Trust for the benefit of his children. The trust provides that, after Brads death, the trust assets will be divided amongst his issue in equal shares, per stirpes. Brad has three children: Henry, Isaac and Julia. The three children have a total of eight children of their own, and seventeen grandchildren. The trust provides that during brads lifetime, the trustee may distribute trust assets to or for the benefit of Brads children, for their health, education, maintenance and support. In addition, the trust may spend or apply trust assets for the benefit of any descendant of Brad whose parents are deceased and who requires such assistance to meet their day to day maintenance expenses. Brad has a large estate that hes trying to gift away and realizes that he may not have many years in which to do so. However, he only wants to gift as much money to the trust each year as would be covered by the gift tax annual exclusion. Brad asks you whether gifts to the trust would be eligible for the gift tax annual exclusion based on the number of children he has, the number of grandchildren he has, the number of great grandchildren he has or some combination thereof. Brad says that you may give anybody you like a temporary right of withdrawal. He does not care, so long as the basic terms of the trust, as stated above, do not change. Please write a letter to Brad (citing appropriate statutory and case law authority) explaining to him the level of annual exclusion that would be applicable to this trust, assuming it is drafted as is and assuming that Brad makes no other gifts to his descendants each year.