What are the gift tax consequences of an irrevocable transfer of $10,000,000 in trust to grantor's son for life, with all income payable to son, then remainder to charity on son's death? Grantor makes no other transfers that year, and grantor is not married.
a. Gift of $10,000,000, less one $13,000 annual exclusion; and deduction for present value of remainder interest to charity as calculated using IRS tables.
b. Gift of $10,000,000, less two $13,000 exclusions; no deduction for remainder interest.
c. Gift to son of present value of income interest, less one $13,000 exclusion.
d. Gift of $10 million, less one $13,000 exclusion; no deduction for remainder interest.