Janet is considering transferring assets valued at $4 million to an irrevocable trust (yet to be created) for the benefit of her son, Gordon, age 15, with Farmers Bank as trustee. Her attorney has drafted a trust agreement that provides that Gordon is to receive income in the trustee's discretion for the next 20 years and that at age 35 the trust assets will be distributed equally between Gordon and his sister Joanna. Janet anticipates that her husband will consent to gift splitting. What tax issues should Janet and her husband consider with respect to the trust