In 2005, Joe who is 75 years old, created a 10 year GRAT into which he transferred $1 million of securities. Joe’s basis in the securities is $250,000. At the time Joe transferred the assets into the GRAT, the IRC Sec. 7520 rate was 4.8%. Joe’s annuity interest was valued at $311,000. At the end of the 10 years, the assets within the trust transfer to Joe’s brothers and sisters.
Assume Joe survives the 10 year retained period. The gift to trust was covered by the unified credit and no gift tax was paid on the transfer to trust. At the expiration of the term, the trust assets are valued at $1,500,000, which the siblings sell for that amount. What is the taxable gain to be recognized on this sale?