Hugh makes the gifts listed below to Winnie, his wife, age 37. What is the amount of the marital deduction, if any, attributable to each?
a. Hugh transfers $500,000 to a trust with a bank named as trustee. All the income must be paid to Winnie monthly for life. At Winnie’s death, the property passes to Hugh’s sisters or their estates.
b. Hugh transfers $300,000 to a trust with a bank named as trustee. Income is payable at the trustee’s discretion to Winnie annually until the earlier of her death or her remarriage. When payments to Winnie cease, the trustee must distribute the property to Hugh’s children by a previous marriage or to their estates.