Taxpayer A ("A") has $100,000,000 cash. On January 1, 2020, A transferred $5,000,000 to trust T. The terms of trust T were that A would receive $1,000,000 per year for 5 years, and at the end of 5 years, the remainder (the assets still in the trust) would be distributed to A's son ("S"). The interest rate ("AFR") at date of transfer was 5%. As it turns out, T earned $500,000 per year (i.e. the remainder was $2,500,000