William funds a trust with property valued at $10,000,000. The income beneficiary is his daughter, Sarah, who has a general power of appointment over the trust. The remainder beneficiary is William's grandson, Tomas. William dies and then Sarah dies. After Sarah's death, the assets are distributed to Tomas. Who pays any GST tax?

A) There is no GST tax.

B) Tomas after the distribution.

C) William's estate.

D) Sarah's estate.