Generally, taxable real estate activities in CA are subject to CA reporting.  

One scenario for "NO need for CA reporting" for the trust: immediately after the TOD, the property was converted to a non-rental property (investment or personal use) by the beneficiaries, and was NOT sold before the year end, while the trust had other non-CA assets.  In this scenario, Form 1041 would be needed but NOT CA 541.  But then, this would be off from the "spirit" of the original question.

There are always possible scenarios for every situation.  That's why we have Hollywood.  That's also why the 49es did what they did.  

Billable work is calling.  And I digress.