Peggy is considering transferring assets valued at $10,000,000 to an irrevocable trust for the benefit of her son Alex. The trust will state that Alex is to receive income in the trust for the next 20 years and that at age 35 the trust assets will be distributed equally between Alex and his sister Cathy. Peggy anticipates that her husband will consent to gift-splitting. What tax issues should Peggy and her husband consider with respect to the trust?