Paula transferred $3,500,000 to a GRAT in 2019 naming her two sons as the remainder beneficiaries, while retaining an annuity presently valued at $860,000. Assuming that Paula had already given $11,400,000 in cumulative adjusted taxable gifts over the years, what portion of this transfer would be considered a taxable gift in 2019?

A. $860,000 B. $1,140,000 C. $2,625,000 D. $2,640,000 E. $3,500,000