Your client wants to create a trust for his two daughters, ages six and eight, respectively. He proposes the following provisions:

(1) the trust income shall be distributed to them or expended for their benefit in equal shares;

(2) the principal may not be invaded until the youngest daughter attains age 21, at which time the trustee is authorized to make distributions of principal to either daughter for the recipients health, education, support, and maintenance;

(3) when the youngest child attains age 35, the remaining trust property is to be distributed to them in equal shares.

Does any portion of the transfer qualify for the annual exclusion? If your client wanted to qualify the entire transfer in trust for the annual exclusion, what changes would be necessary?