In 2012, client creates a 10-year QPRT into which his primary residence is transferred. The value of the residence on the transfer date was $1 million. Since the client is a widower, the residence is far too large. As a result, the Trustee sells the residence and purchases a smaller residence for $500,000.
What effect does the sale have on the QPRT?
a. Nothing.
b. The QPRT is disqualified and all of the assets revert to the Grantor.
c. The QPRT is disqualified and all of the assets transfer to the trust beneficiaries.
d. The Grantor retains the right to live in the smaller residence for the remaining term; the excess sale proceeds must be distributed to the Grantor or converted into an annuity interest for the Grantor.