In 2014, Daryl bought a life insurance policy on his life with a death benefit of $1,200,000. He named his wife Melanie the beneficiary of this policy. In 2017, Daryl created an ILIT with Melanie as beneficiary, and transferred all incidents of ownership in the policy to the trust. The ILIT gives Melanie a lifetime income interest and a general power of appointment over the trust corpus. The value of the policy was $360,000 at Daryl’s death in 2018. Which of the following statements are correct?

A.    The death benefit amount is included in Daryl’s estate but a marital deduction is available to offset the tax.

B.    The value of the policy is included in Daryl’s estate and a marital deduction is not available to offset the tax.

C.    When Melanie dies, the value of the trust will be included in her estate.

D.    When Melanie dies, the value of the trust assets will not be included in her estate