1. The grantor's remaining gift and estate tax exemption could offset this but this would reduce the grantor's remaining exemption available for future gifts and bequests.
2. A remainder beneficiary inherits trust assets either outright or in an ongoing trust, after the current beneficiary passes away or no longer has an interest in the trust.
3. In addition to the appropriate distribution and other provisions in the trust, generation-skipping transfer tax (GSTT) could be allocated at the initial funding, providing for maximum tax efficiency.
4. Payment of estate taxes is a common motivation, but not the only motivation, for purchasing life insurance within an irrevocable trust.
5. In a GRAT, the remaining assets at the end of the term typically distribute to children rather than grandchildren or more remote descendants, as the GSTT exemption cannot be allocated to the GRAT until the end of the term.
6. Valuation is discounted for minority discount, lack of control and lack of marketability.
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