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To what extent, if at all, do the following transactions constitute transfers subject to gift tax at the time of the transfer? Near Ds death,
- To what extent, if at all, do the following transactions constitute transfers subject to gift tax at the time of the transfer?
- Near Ds death, which as anticipated, occurred one year later, D gave an insurance policy on Ds life to Child C.
- D transferred securities to a trust, retaining the right to the income for Ds life and providing for payment of the corpus at Ds death to unrelated X or Xs estate.
- D transferred securities to a trust under the terms of which the income was to be paid to unrelated X for Xs life. Upon Ss death, the corpus was to be returned to D if D was living, and, if not, was to be paid over to unrelated Y or Ys estate.
- D transferred securities to a trust under the terms of which the income was to be paid to S for Ss life. Upon Ss death, the remainder was to go to X or Xs estate. However, D retained an unlimited right to alter the terms of the trust in any manner.
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