This year Noah transferred $7 million to an irrevocable trust established for the benefit of his niece. The trustee is directed to accumulate income for the next five years before distributing the before distributing the trust corpus to Noahs niece. In past years Noah has made taxable gifts of $6 million and used an applicable credit on an exemption equivalent of $5 million. What amount of gift tax, if any, must Noah remit?

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