NIIT and gifting stocks avoid tax

Hi,

I am in a somewhat unique (at least unique in my experience) where I am married filing separately (for spouse student loan forgiveness reasons). My income is much higher than my spouses and am looking to offload some mutual funds from my own individual brokerage account to hers since my income already exceeds the NIIT income threshold that triggers 3.8% tax. Hers however has some room before it triggers so I guess my 2 questions are:

1) Can I "gift"/transfer say $100k in stocks or will this be treated like gifting in general (up to $19k/year per individual and anything over requires filing for gift tax"

2) Is there any issue trying to go about it this way to avoid the 3.8% tax (legally sound or is there a concern)

Any guidance is appreciated!