Which one of the following transfers will not be subject to the generation-skipping transfer tax (GSTT)?

A) A taxpayer establishes a trust and names their self as the income beneficiary and their grandchildren as the remainder beneficiaries.

B) A transfer by a taxpayer to a UTMA account established for the benefit of her granddaughter. The account is managed by the granddaughter's parent (the taxpayer's adult child).

C) An irrevocable trust that pays income to the taxpayer for 10 years and then pays the remainder to her lifelong friend, who is 40 years older than her.

D) An irrevocable trust that pays income to taxpayer's daughter for life, then distributes the remainder to the grandchild.