Winston and Rocco are in a committed relationship but their state of residence does not legally recognize their relationship. Winston has an estate worth $5 million and he wants to transfer a portion of his wealth to Rocco. Which estate planning strategy is not available to Winston to achieve this objective?

A. Winston can establish a testamentary bypass trust in his will and name Rocco as beneficiary.

B. Winston can establish a CRAT that provides Rocco with an income stream for a number of years, and his favorite charity with the remainder interest.

C. Winston can establish a trust that gives Rocco the income for life and his niece the corpus at Rocco's death, and make a QTIP election on his gift tax return to reduce the

taxable amount of the gift.

D. Winston can transfer appreciating assets to a GRIT with Rocco as beneficiary.