Foreign stock award and Form 3520

[taxcurious]

Hi there,

I am a Canadian living in the USA (filing as a USA resident; I have already departed Canada). I work for a company that had an IPO on the London stock exchange while I was working for them. As a result of the IPO, I received a modest amount of shares from the company (~$5000 worth) that had both a i) vesting date, and a ii) lockup period (period during which I could not sell the shares). The company filed an 83(b) election for me so that the stock award was taxed when it was granted as income, and the company paid all the tax on the shares.

My question: since the stock was held somewhere for me (I'm assuming the UK) during the vesting/lockup periods before it was transferred into my name, does this count as a foreign trust (and thus induce the requirement to file 3520/3520A)? I read the docs and the shares were in the name of a "nominee" and after the lockup period they were released to me. I understand this is a pretty niche question, just wondering if anyone might have some insight - thank you.