Mr. OG, a 66-year-old divorced individual, has two children with his former wife. He recently married a 45-year-old woman with no property of her own. Therefore, Mr. OG plans to change his will to provide that when he dies, his fortune will be placed in a trust. His new wife will receive the income for as long as she lives, but she has no direct ownership in the trust property. When she dies, Mr. OG's two children will inherit everything.

Identify the tax issue or issues suggested by the above situations, and state each issue in the form of a question.