Robert Cooper, a widower, died this year at the age of 95. The value of his estate was estimated to be between $50 million and $80 million. Robert’s will appointed William Sawyer as his personal representative. William will be responsible for filing the estate tax return for Robert’s estate, and William is seeking your help with the following:

1.   In 1996, Robert purchased a life insurance policy naming his daughter Cara as the beneficiary. The policy is worth $5 million. In 2020, Robert transferred all rights to the policy, including the right to change beneficiaries, to Cara. Cara has been paying the premiums on the policy since 2018.

2.   Robert owned intellectual property rights to several artistic works when he died. He also had an extremely valuable art collection including original work not only from himself but from artists such as Salvador Dali, Roy Lichtenstein, Joan Miro and Pablo Picasso.

3.   In 2004, Robert transferred the rights to his home in Los Angeles to his daughter Cara when it was worth $20 million. The terms of the transfer of the property included a provision that Robert could live in the house for as long as he wanted. Robert moved from the house to a nursing home in 2011, when he was no longer able to care for himself.

4.   In 2001, Robert created a trust transferring various real estate and stock worth a total of $7 million. William was the trustee of the trust and Cara was the beneficiary, but Robert retained the right to change the beneficiary at any time.

5.   In 2018, Robert made a large gift to Paige Matthews (his friend and neighbor). The gift was an art piece valued at $1.2 million. Because Robert had made several sizable gifts during his lifetime, the $1.2 million gift was taxable. Robert paid $480,000 in gift tax on the transfer, which he properly reported.

Please advise William on the estate tax consequences of the above transactions. Be sure to discuss what steps she needs to take to report proper values of property, where appropriate. Be sure to explain your answers.