Diego is a single individual who owns a life insurance policy worth $1.5 million that will be worth $8 million upon his death. This year Diego transferred the policy and all incidents of ownership to an irrevocable trust that pays income annually to Diego’s two children for 15 years and then distributes the corpus to the children in equal shares.

a) Calculate the amount of gift tax due (if any) on the transfer of the insurance policy. Assume that Diego has made only one prior taxable gift of $12 million in January of 2018.

b) Diego died unexpectedly this year after transferring the policy. At the time of death, Diego’s probate estate was $25 million, to be divided in equal shares between Diego’s two children. Calculate the amount of cumulative taxable transfers for estate tax purposes.