I've figured out the solution, as I was approaching it incorrectly.  I correctly chose this as an indirect skip trust; meaning that I could allocate GST exemption, but it does not currently trigger a GST tax.  While the transfer will trigger gift tax owed, it will not trigger GST tax owed until there is a taxable distribution or taxable termination at some future date to a beneficiary who is a skip person.  At which point, only the portion of the trust not exempt to GST tax (based on the applicable inclusion ratio) (i.e. the amount not sheltered (including any applicable appreciation thereon) by the Section 2632(c)(3) allocation of the client's remaining GST exemption) would be subject to the GST tax.