DSNG Separate Share Rule
A transfer to trust does not qualify as a DSNG however unless it is distributable only to that individual during his life and the trust assets will be includable in that individual's federal gross estate if he dies before the trust terminates. 26 U.S.C. § 2542(c)(2)(A)–(B).
Just because a transfer to trust is eligible for for the annual exclusion amount does not mean that it is a DSNG.