—Guide
Reporting Foreign Assets in Your ITR: Schedule FA, RSUs and the Black Money Act
What Indian residents must report in Schedule FA, the calendar-year rule, how RSUs and foreign accounts are treated, and the Black Money Act penalties.
If you're an Indian resident with a foreign bank account, shares in a foreign company, RSUs, or property abroad, you must report them in your income-tax return — even if they earned nothing. The penalties for not doing so are among the heaviest in Indian tax. This guide explains the rules.
Who Must Report
Residents who are ordinarily resident in India — including individuals, HUFs and companies — with foreign assets or foreign income. Individuals who are 'resident but not ordinarily resident' generally don't need to report foreign assets in Schedule FA.
What to Report in Schedule FA
- Foreign bank and depository accounts.
- Foreign custodial accounts, like brokerage accounts.
- Shares and debt interests in foreign entities, including RSUs and ESPP shares of a foreign employer.
- Foreign mutual funds and insurance policies with cash value.
- Financial interests in foreign entities and trusts.
- Foreign immovable property.
- Accounts over which you have signing authority.
The Calendar-year Rule
Schedule FA is filled on a calendar-year basis: for the return for FY 2025-26, report assets held at any time during January to December 2025. Values reported include the peak balance or value and the closing value for that calendar year.
Foreign Income
Income from foreign sources is reported in Schedule FSI, along with foreign tax credit claimed, and must be included in taxable income.
The Black Money Act
The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 imposes tax at a high rate and significant penalties on undisclosed foreign income and assets. Failing to report foreign assets in the return can itself attract a penalty.
Small-holding relief
From 1 October 2024, the penalty for failing to report foreign assets doesn't apply where the aggregate value of foreign assets, other than immovable property, is ₹20 lakh or less. The reporting obligation itself still applies.
Common Mistakes
- Not reporting RSUs held in a foreign brokerage account.
- Using the financial year instead of the calendar year.
- Using ITR-1, which can't be used by those with foreign assets.
- Forgetting small or dormant foreign accounts.
Getting Help
Think Filing prepares Schedule FA and FSI for residents with foreign assets, and advises on correcting past years.