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Robert transferred $15,000,000 to a GRAT in 2022. His two children are the remainder beneficiaries of this trust. What is the present value of the

Robert transferred $15,000,000 to a GRAT in 2022. His two children are the remainder beneficiaries of this trust. What is the present value of the annuity interest Robert should retain if he wishes to avoid paying gift taxes on this gift? Assume no previous taxable gifts have been made.

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