It shall be the duty of the executor of every person who may die a resident of Vermont or a nonresident with real estate or tangible personal property having an actual situs in Vermont to file with the Commissioner a duplicate of all federal estate tax returns that he or she is required to make to the federal authorities or, if no federal estate tax return is required, a pro forma federal estate tax return for the estate of a decedent with a Vermont estate tax liability shall be filed with the Commissioner.
32 V.S.A. § 7445