My brother leaves in Europe and is not subject to an kind of U.S. income tax filing. On the other hand, I live in the USA and that's where I have my tax returns filed.
We would like to purchase a small apartment complex in Europe, renovate it, and then rent it out.
Would my brother (or myself) have to disclose any kind of information about him to the U.S. IRS, FinCEN, or whoever else? What information?
Neither the Fincen 114 (reporting an interest in foreign financial accounts nor the Form 8938 (reporting specified foreign financial assets) requires you to report anything about the foreign partners.
You most probably are required to file Form 8865 (Return of U.S. Persons With Respect to Certain Foreign Partnerships) because of the attribution rules for family members. I think that your brother's interest (related party) in the partnership is attributed to you for purposes of filing this form. This would make you a Category 1 filer. Filing this form negates the requirement to file the 8938 for that same partnership interest. That being said, this form also does not require any information on the foreign partners.
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