Clara and Andy have been married for 43 years. Many years prior to his death in 2024, Andy made $6MM in adjusted taxable gifts to non-skip persons. At the time of his death, Andy's adjusted gross estate was worth $20MM. What is the optimum means for utilizing Andy's $13.61MM Generation Skipping Transfer Tax exemption?

a. Port Andy's $13.61MM GST Exemption to Clara

b. Create a bypass trust with $7.61MM, a Reverse Q-Tip Marital Trust with $6.0MM and a Regular Q-Tip Marital in the amount of $6.39MM. Apply GST Exemption to bypass and Reverse Q-Tip trusts equal to the funding amounts.

c. Create a bypass trust with $13.61MM. Apply GST Exemption in full to this trust.

d. Create a bypass trust with $7.61MM and a Regular Q-Tip Marital Trust with $12.39MM.