Reference no: EM131546273

At his death in 2017, Grandfather's estate plan established a trust for the benefit of his dauther and his grandchildren that was funded with $20,000,000, after all the Grandfather's debts expenses and estate taxes had been paid. The trust provided that the income from the trust be distributed to Daughter for the life of Daughter. After Daughter's death, the principal of the trust would be distributed to Daughter's children, Grandson and Granddaughter, in equal shares. Assume that Granddaughter had made no taxable gifts to his grandchildren prior to his death and that when daughter dies the trust assets (taxale transfer) will still be worth $20,000,000.

1) After applying the Generation Skipping Transfer Tax exemption for 2017, what amount of grandfather's estate would be subject to Federal GST Tax at the death of daughter?

2) What type of generation skipping transfer occurs when daughter dies?

3)(a) if grandfather had made additional gifts to his grandchildren in 2017 before he died in the amount of $1,000,000 to each grandchildren, what amount of GST tax exemption was available when Grabdfather died?

(b) what amount of trust estate then be subject to Federal generation skipping transfer tax at the death of Daughter?

4) (a) If the trust for the daughter allowed periodic distrubutions of principal to Granddaughter and Grandson during Daughter's lifetime, and gifts of $500,000 were made to each before Daughter's death, what types of transfers would each gifts be?

(b) Who would pay the GST Tax on the distribution of Granddaughter and Grandson?

5) Instead of creating a trust, if Grandfather's estate plan provided for an outright gift to Daughter in the amount of $10,000,000 and outright gifts to grandson and granddaughter in the amount of $5,000,000 each waht type of generation skipping transfers are the gifts to the Grandchildren?