In 2003, Carl transfers $1,500,000 to a trust, granting income to Edward for life, remainder to Tom or Tom's estate. Carl also gives Edward an annual right to withdraw up to $75,000 from the trust for the first five years only. Edward does not exercise his rights and they lapse. Edward dies in 2011, when the trust property is worth $2,500,000 and has never fallen below $1,500,000 in value. Does Edward have any gift or estate tax consequences at any point in time as a result of these facts?