What is the applicable fraction

Reference no: EM133354131

Question: T transfers $12,060,000 to an irrevocable trust. The instrument provides the trustee with the discretion to distribute income or principal to T's children and grandchildren. T timely files a gift tax return and elects to allocate $6,030,000 of his GST exemption to the transfer.

a. What is the applicable fraction?

b. What if T filed a timely gift tax return, but did not allocate any exemption to the transfer in trust until two years later, when the value of the trust was $6,030,000?

c. Same facts as (b), except that the value of the trust property on the date of allocation is $24,120,000.

Reference no: EM133354131

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