In 2020 individual D ("D") transferred $10,000,000 to an irrevocable trust which pays income to D's adult daughter, S, during D's life, as needed to provide for S' enjoyment, with remainder to S' children (A and B) in equal shares upon D's death. D named himself as Trustee. In 2021, the trust distributed $150,000 to S. In 2022, the trust distributed $300,000 to S and in 2023, D died while the trust was valued at $11,000,000 and D's estate distributed $5,500,000 to each of A and B.

Which of the following is a correct statement?

a. D made a completed gift of $10,000,000 in 2020 for which no annual exclusion will be allowed

b. D made a completed gift of $150,000 in 2021 for which no annual exclusion will be allowed

c. D made a completed gift of $300,000 in 2022 for which the annual exclusion is permitted

d. D will include $10,450,000 in D's gross estate