Hello and thank you for using Just Answer.As one of the more confusing areas of US tax the Form 3520 is near if not at the top of the list.Form 3520 is required to be filed by any U.S. person who is "…treated as the owner of any part of the assets of a foreign trust under the grantor trust rules." Thus, a grantor of a foreign trust must file this form every year in addition to Form 3520-A . So under this portion you apper to have been laible for filing when you resieved partial title.
You could fall back on the foreign countries laws as to whether you really had any ownership until the end.
The law of the other country that you were not an owner or received the authority over the property. If you can perhaps show that you did not recieve the ownership until 2011.
You may need to retain a tax professional in your area should you need to argue this point with the non reporting in past year.
Then if questioned those could be valuable. I cannot promise you that they will be all or enough.
I have never had to professional argue this, so I suppose I would have to say strickly academic.
I do feel comfortable with my interpretation. Can I cite anytime when I argued a person's validity to not have filed (as your circumstance) no.
I feel comfortable with my interpretation. As I stated though, I have never argued this to IRS.