Sebastian died in 2021. In his will he established a trust for the benefit of his children.
Question:
Sebastian died in 2021. In his will he established a trust for the benefit of his children. He funded the trust for his children with $25,000,000. The trust provided that the children receive income earned from the trust assets for a period of 10 years, after which the principal balance of the trust would be distributed outright to Sebastian's 10 grandchildren, in equal shares. In his will, Sebastian also made additional outright gifts to each of 10 grandchildren in the amount of $100,000 each to be distributed to the grandchildren immediately after Sebastian's death. Later in 2021, the trustee of the trust for Sebastion's children made an additional distribution of trust principal to each of the grandchildren in the amount of $100,000 to each grandchild. For Generation Skipping Transfer Tax purposes only, Sebastian's gift of $100,000 to each of his grandchildren immediately after his death is what type of transfer?
The trustees' distribution of an additional $100,000 to each of the grandchildren in 2021 were what type of transfers?'
The trustee's distribution of the principal balance of the trust to the grandchildren after 10 years will be what type of transfer?
Who would be responsible for paying any GST tax on the $100,000 gifts to the grandchildren immediately after Sebastian's death?
Who would be responsible for paying the GST tax on the additional $100,000 distributions to each grandchild from the trust in 2021?
Who would be responsible for paying the GST tax on the balance of the trust funds distributed after 10 years?