1. D transferred $5,000,000 to an irrevocable trust on January 1 of 2022. Under the terms of the trust D retained an annual payment of $500,000 per year, payable on the last day of the year, for five years, with the remainder going to D's child ("C"). (It is also assumed that the trust stated that if D died, the annuity payments would continue to be paid to D's estate - a "fixed term annuity"). Assume that the trust has actual income of $200,000 in each of the 5 years ('22, '23, '24, '25, and '26) and that the fair market value ("FMV") of the trust decreases by $100,000 (including the $500,000 distribution to D) in each year. Meaning that at the end of five years trust principal is $4,500,000. (The 7520 rate is 1.6%).
2. What are the gift tax consequences to D, if any? ______________________
3. What are income tax consequences to D, if any in 2023? _____________
4. What are the estate tax consequences to D if any (meaning what, if anything will be included in D's estate, if D dies in 2029)? _______________________________________________