Death of US Citizen resident of Canada >> Estate?

[neoplop]

Say a US citizen who has resided in Canada most of her life dies. I understand her final 1040 is filed, and possibly a form 706 Estate Tax Return.

But what about after this? Income (dividends, interest, etc) in her Estate earned after death are reported on a T3 Trust Return in Canada. But what about the US?

Is the Estate of a Decedent who was a US citizen considered to be a DOMESTIC Trust to the US and therefore must continue to file 1041 returns until the estate is distributed? Even though the estate was created under the laws of Canada?

Or is it considered a FOREIGN trust and therefore only liable for US tax returns to be filed if there is US-source income?

Got all the way to the Complex Individual Issues department at the IRS, but they did not know.

Thank you for any input!

[nelsona]

If she dies in canada, her estate become a foreign trust, with all the foreign trust reporting that must be done, by the estate and the trustee.