Your client Esther is single and has assets worth $22.4 million dollars before making any gifts. She made a gift to her son William of $6 million dollars in 2021. She dies in 2022 and her will states that her estate is to make a $2 million dollar contribution to the American Cancer Society and $1 million to the Ohio University Foundation. She also has provided that in her will to leave $2,000,000 to her nephew Ed. The balance, after any taxes, goes to his son. Your client has not made any taxable gifts in any prior years.

a. Ignoring the $15,000 annual gift exclusion, calculate the 2021 gift tax on the transfer to his son

b. Again, ignoring the $15,000 annual gift exclusion, calculate the estate tax upon your clients death in 2022.

c. How much will William receive from her estate?

d. What would the estate tax have been if your client did not make the gift in 2021, but instead just held onto the assets?