In 1993, Eve created a single irrevocable trust for the benefit of her two children and five grandchildren. The trust terminates upon the expiration of a 21-year period after the last to die of Eve's two children and five grandchildren who were living at the time the trust was created. The trust was originally funded with $1MM, and Eve applied $500,000 of her GST Exemption against this trust on the Form 709 that she filed.

Eve's first child passed away in 2007, and her second child passed away in January 2019. The value of the irrevocable trust's assets at the death of her second child was $5,435,000.

What are the Generation Skipping Transfer Tax consequences of this trust arrangement following the death of Eve's second child last month? Please be specific.