Loretta, age 75, owns a vacation residence on the Hawaiian Island of Kauai valued at $4.5 million. She would like to place the vacation residence in a 5 year QPRT with the remainder passing to her 5 grandchildren in equal shares. What are the implications of this transfer? a. Loretta will need to apply $4.5MM of her GST Exemption to the QPRT at inception of the trust. b. If a parent of two of the grandchildren should die during the 5 year QPRT term, these two grandchildren will become non-skip persons. c. GST Exemption cannot be applied to the QPRT until it terminates at the end of 5 years. d. If the vacation residence appreciates to $8MM at the end of 5 years, Loretta will owe additional gift tax on the increased value.