In 2019, Barry creates an irrevocable trust for the benefit of his children and grandchildren with $400,000 of assets. Barry allocates $400,000 of his GST Exemption to this trust when filing Form 709. If the trust appreciates to $4,000,000 in 2024, and a distribution of trust principal in the amount of $450,000 is made that year to one grandchild, what are the GST implications of this situation? a. 100% of the distribution will be subject to GST tax. b. 10% of the distribution will be subject to GST tax. c. $50,000 of the distribution will be subject to GST tax. d. None of the distribution will be subject to GST tax.