Neither taxpayer A nor taxpayer B have a federal tax liability for gifting more than the annual exclusion amount.
So I do not see how the gift tax, which would implicitly involve a tax liability for the gift, has a limit of $17k.
Am I incorrect?
If A is alive when that happens then that is wrong. B will be taxed on the amount of $1M - 17k because the gift tax applies not the estate tax.
If A were dead and gifted B in their will, then you would be correct because the estate tax applies in this scenario.
Again, since we're taking about loans and gifts while a person is alive in this thread, the first scenario of the gift tax applies.
https://www.irs.gov/businesses/small-businesses-self-employe...
>Who pays the gift tax?
> The donor is generally responsible for paying the gift tax. Under special arrangements the donee may agree to pay the tax instead. Please visit with your tax professional if you are considering this type of arrangement.
But given we're talking about loans and gifts while a person is living, I think the correct tax to invoke is the gift tax that has a limit of $17,000 per year.
https://www.irs.gov/businesses/small-businesses-self-employe...