CA estate w/ mostly-US-resident executors: domestic trust?

[AlejoHausner]

My wife's mother died and left three executors to her will. She was a Canadian resident, and all her assets were in Canada.

Two executors are US residents, and one is a Canadian resident. The CRA considers the estate to be a "non-resident", because more than 50% of the EXECUTORS are not Canadian residents.

My questions are:

1. Does the IRS consider the estate to be a domestic trust? Looking at page 2 of the instructions for IRS form 3520, a trust is domestic if "2. One or more U.S. persons have the authority to control all substantial decisions of the trust."

Does a majority of US-resident executors on a Canadian estate imply that the estate is a US estate?

2. My wife is a legatee. If the answer to #1 is yes, will the estate owe US taxes when she receives money from it?

We're pretty confused about this.