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 $1,000,000 in 2022, and a distribution of trust income is made to one grandchild, what are the GST implications of this situation?

	a. 100% of the income distribution will be subject to GST tax.
	b. 40% of the income distribution will be subject to GST tax.
	c. 60% of the income distribution will be subject to GST tax.
	d. None of the income distribution will be subject to GST tax.