Decedent dies with an estate equal to $15,000,000 in 2021. He has made $500,000 of taxable gifts protected by the unified credit. A bypass trust equal to $4,750,000 is created. The balance of the estate passes to trusts for which a QTIP election is made. Assume all trusts would be subject to generation-skipping transfer tax, except to the extent that the generation-skipping transfer tax exemption is allocated to the transfers. For generation-skipping transfer tax purposes, in 2021, a reverse QTIP election should be made with respect to