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What are the federal gift tax consequences of the following: Assume S creates an irrevocable inter vivos trust, under which the trustee is to pay

What are the federal gift tax consequences of the following:

Assume S creates an irrevocable inter vivos trust, under which the trustee is to pay income to A, or accumulate the income and add it to the corpus in the trustee's discretion, and pay the corpus to A at the end of 5 years. 

Required: Does the trust qualify for an annual gift exclusion?

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As previously mentioned to qualify for the annual exclusion a gift must be a gift of a present interest which simply means that the recipient must eit... blur-text-image

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