On January 1, 2010, Father transfers $100,000 to each of Trust A and Trust B. Trust A provides mandatory distributions of income for Son A’s life, and, at his death, the remainder is distributed to his children. Trust B provides mandatory distributions of income for Son B’s life, and, at his death, the remainder is distributed to his children.

On Father’s 2010 form 709, Father affirmatively allocates $100,000 of GST exemption to Trust A. Father does not affirmatively allocate GST exemption to Trust B and elects not to treat Trust B as a GST trust (thereby electing out of automatic allocation).

On January 1, 2015, the fair market value of the assets held in Trust A is $200,000. On January 1, 2015, the fair market value of the assets held in Trust B is $200,000. On January 1, 2015, Father affirmatively allocates $100,000 to Trust B.

What are the inclusion ratios of Trust A and Trust B as of January 1, 2015?

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