Ruby established an inter vivos irrevocable trust earlier this year that gave her husband, as the sole income beneficiary, a lifetime right to all income payable on an annual basis. Ruby named her children as remainder beneficiaries. She also gave her husband a general power of appointment over all trust assets during his lifetime and at his death. She funded the trust with $1,000,000 in cash and assets.

Which one of the following most closely approximates Ruby's taxable gift for this transfer?

A)

$1,000,000

B)

$500,000

C)

$0

D)

$345,800