I agree with @sjrcpa that no return is required.  Some time in the last decade, or maybe in the last millennium, IRS may have sent a notice to a sample of trust EIN applicants who didn't file returns, asking why not.  They probably got a lot of "no income" responses, and decided such a project is not worth the postage.  But now the OCD branch of the Preparer Community thinks every EIN deserves a return.  And of course, they have as evidence the fact that IRS sends ES forms to trusts and estates that might have owed tax six years ago.