You are correct. Unless your wife received more than $100,000 from a nonresident alien individual, then she is not required to file Form 3520
From Instructions for Form 3520 (2020) Annual Return To Report Transactions With Foreign Trusts and Recei...
Who Must File
File Form 3520 if any one or more of the following applies.
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You are the responsible party for reporting a reportable event that occurred during the current tax year, or you are a U.S. person who transferred property (including cash) to a related foreign trust (or a person related to the trust) in exchange for an obligation or you hold a qualified obligation from that trust that is currently outstanding.
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You are a U.S. person who, during the current tax year, is treated as the owner of any part of the assets of a foreign trust under the rules of sections 671 through 679. U.S. person and owner are defined later.
Complete the identifying information on page 1 of the form and Part II. See the instructions for Part II.
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You are a U.S. person (including a U.S. owner) or an executor of the estate of a U.S. person who received (directly or indirectly) a distribution from a foreign trust during the current tax year; or you are a U.S. person who is a U.S. owner or beneficiary of a foreign trust and in the current tax year you or a U.S. person related to you received (1) a loan of cash or marketable securities (including an extension of credit) directly or indirectly from such foreign trust, or (2) the uncompensated use of trust property; or you are a U.S. person who is a U.S. owner or beneficiary of a foreign trust and in the current tax year such foreign trust holds an outstanding qualified obligation of yours or a U.S. person related to you. For definitions, see U.S. Person, Owner, Distribution, U.S. Beneficiary, and Related Person, later.
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You are a U.S. person who, during the current tax year, received either:
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More than $100,000 from a nonresident alien individual or a foreign estate (including foreign persons related to that nonresident alien individual or foreign estate) that you treated as gifts or bequests; or
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More than $16,649 from foreign corporations or foreign partnerships (including foreign persons related to such foreign corporations or foreign partnerships) that you treated as gifts.
