Question: Donor places $500,000 worth of closely held stock into an inter vivos trust with a qualifying income interest to Spouse for life and a remainder to the children of Donor's first marriage. Assume annual exclusion amount is $12,000.
(a) What are the gift tax consequences to Donor if Donor makes a §2523(f) election?
(b) What are the gift tax consequences to Spouse in (a) if Spouse gives the entire life estate to X prior to death? Assume the income interest is worth $200,000 and the remainder interest is worth $300,000.
(c) What are the estate tax consequences to Spouse in (b)?
(d) What are the estate tax consequences to Spouse in (a) if Spouse dies without making an inter vivos disposition of the life estate?