George creates a trust with the following terms:

• After his death, income and principal can be distributed to his wife, Lucille.
• Upon Lucilles death, trustee can distribute income and principal for their children, Lindsay, Michael, and Gob.
• When the children have all passed away, the trustee can distribute income and principal for George and Lucilles grandchildren, Maeby and George Michael.
• Upon the death of Maeby and George Michael the trustee can distribute income and principal for any children that they may have.

The trust is funded with $1,000,000. George has not used any of his GST exemption previously and timely files a 709 allocating $1,000,000 in exemption to the trust.

Which of the following is true?

a. Because Lucille is the initial beneficiary, the trust is not ever subject to GST tax.

b. Upon the death of Lindsay, Michael, and Gob the funds in the trust will be subject to GST.

c. Upon the death of Maeby and George Michael the funds in the trust will be subject to GST.

d. Because George has allocated GST to the trust upon inception, the funds will never be subject to GST.