In 2011, while he was still living, Leon funded an $8,000,000 irrevocable trust for the benefit of his only daughter. In the event of daughters death, the trust would benefit her children (Leons grandchildren).

a. What is the GST and/or gift tax due on the formation of this trust? Assume no GST exemption was allocated to this trust when it was funded.

b. In 2015, Leons daughter died. Leon was still alive when his daughter died. The value of the trust had increased to $15,000,000. What should Leon do to minimize this trusts exposure to the GST?

c. Assuming, contrary to what actually happened, EGTRRA had been allowed to sunset prior to daughters death, what should Leon do to minimize this trusts exposure to the GST?

d. Again, contrary to reality, assuming that EGTRRA had expired, but that the GST exemption in 2015 was $5,430,000, what could Leon do if he saw that his daughter was not likely to survive? When would such action need to be taken?

e. What if Leon died prior to his daughters illness and death?