The holidays can be a strange time if you're related to someone you don't get along with. Maybe they're not a blood relative, but an in-law or a family friend who got into it with you one too many times, no matter the connection, gifting someone you're not genuinely close to can feel like a minefield.
While there is certainly the option to protest by not gifting them in the first place, that gives them the satisfaction of directly confronting your seething hostility. A more strategic and cunning move is to buy (or make) them a gift that will communicate distaste, but with enough subtlety they have a hard time kicking back. This is holiday psychological warfare 101.
Gift card with a very low amount to an extremely expensive store (like Saks Fifth Ave). Maybe $5 worth.