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Estate Finance Family Tax Plan Question

5. In 2019, Grandfather makes the following transfers:

• $30,000 to Grandson 1.
• $20,000 to American University for Grandson 2's college tuition.
• $30,000 to the Granddaughter's Trust. Granddaughter can withdraw up to $15,000 from the trust upon the contribution and such withdrawal right lapses at the end of the year. Granddaughter's Trust provides income to Granddaughter for her life. Upon her death, the remainder is distributed to Granddaughter's estate.
• $30,000 to the Grandson 3's Trust. Grandson 3's Trust provides income and principal to Grandson 3 at the trustee's discretion. Upon his death, the remainder is distributed to grandson 3's issue.
• $30,000 to Son's Trust. Trustee must distribute income of Son's Trust to Son for his life. At Son's death, the remainder is distributed to his issue.

Assume that Grandfather has no GST exemption remaining in 2019 and that he has sufficient gift tax exclusion to cover the transfers (I know that's not possible because of inflation adjustment additions to GST exemption, but assume for the sake of this question). Also assume that the annual exclusion amount under 2503(b) is $15,000 in 2019. How much GST tax is owed as a result of each of these 2019 transfers and who is responsible for paying them? Discuss the tax liability associated with each transfer including whether the transfer is a direct skip and whether the transfer qualifies for the GST annual exclusion under 2642(c).

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