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Foreign Assets & Income Disclosure for Residents

Reporting of foreign assets, foreign bank accounts, ESOPs / RSUs and foreign income; Black Money Act compliance.

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Handled by a practising Chartered Accountant or Company Secretary.

Scope of work

Reporting of foreign assets, foreign bank accounts, ESOPs / RSUs and foreign income; Black Money Act compliance.

Key deliverables

  • Disclosure schedules and compliance note

Governing law

Income-tax Act (1961 / 2025, as applicable to the period); Black Money Act, 2015

Frequency

Annual

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REGISTRATION ONLY

Foreign Assets & Income Disclosure for Residents

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  • Disclosure schedules and compliance note
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REGISTRATION + COMPLIANCE CARE

Foreign Assets & Income Disclosure for Residents + Compliance Care

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+ ₹9,599/yr for year-one ROC compliance

  • Disclosure schedules and compliance note
  • Financial statements in Schedule III format
  • Board report and AGM notice
  • Filed AOC-4 with SRN
  • Filed MGT-7 / MGT-7A with SRN
  • Board and AGM minutes
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—A closer look

Understanding foreign asset and income disclosure

Everything below is written for Indian residents with foreign bank accounts, shares, RSUs, or property — what must be reported, how, and what happens if it isn't.

What is foreign asset and income disclosure?

Indian residents who are ordinarily resident must report their foreign assets and foreign income in their income-tax return — foreign bank accounts, shares and RSUs in foreign companies, foreign mutual funds, foreign property, interests in foreign entities, and signing authority over foreign accounts.

This applies even if the asset earned nothing, and even if no tax is due. The Black Money Act imposes heavy penalties for failing to report, so getting it right matters even for relatively small holdings.

The key terms

The main reporting rules:

Who must report
Individuals who are resident and ordinarily resident, and other residents such as companies, with foreign assets or income.
Schedule FA
The schedule in the income-tax return listing foreign assets — accounts, securities, property, and other interests.
Calendar-year basis
Foreign assets are reported for the calendar year ending during the financial year — for FY 2025-26, January to December 2025.
Schedule FSI
The schedule reporting foreign-source income, along with any foreign tax credit claimed.
RSUs and ESOPs
Shares of a foreign employer, including unvested awards in some cases and vested shares held with foreign brokers, are foreign assets to report.
Black Money Act
The law governing undisclosed foreign income and assets, with tax at a high rate and significant penalties.
Small-holding relief
The penalty for non-reporting doesn't apply where the aggregate value of foreign assets, other than immovable property, is ₹20 lakh or less — though reporting is still required.

A simple example

A Hyderabad engineer at a US tech company's Indian subsidiary receives RSUs that vest into a US brokerage account, and has a small US bank account from a previous posting. As a resident and ordinarily resident, they report the brokerage account, the shares held, and the bank account in Schedule FA for the calendar year, even though they didn't sell any shares. Dividends received on the shares are reported in Schedule FSI, with credit claimed for US tax withheld through Form 67.

Why it matters

Foreign asset reporting carries some of the highest penalties in Indian tax:

Heavy penalties
Failing to report foreign assets can attract a penalty under the Black Money Act, subject to the small-holding relief.
Undisclosed income
Undisclosed foreign income or assets can be taxed at a high rate with further penalties.
Information exchange
India receives financial account information from many countries automatically, so foreign accounts are visible to the department.
RSUs are often missed
Employees of foreign companies frequently don't realise their RSUs and brokerage accounts must be reported.
No tax doesn't mean no reporting
Assets must be reported even if they earned no income.
Calendar-year trap
Using the financial year instead of the calendar year for Schedule FA is a common error.
Wrong ITR form
Residents with foreign assets can't use the simplest return form.

Who is this for?

  • Employees of foreign companies with RSUs, ESOPs, or ESPP shares
  • Returning NRIs with foreign bank, retirement, or investment accounts
  • Residents investing abroad through the Liberalised Remittance Scheme
  • Residents owning foreign property
  • Directors or signatories of foreign accounts

Returning NRIs who qualify as 'resident but not ordinarily resident' generally don't need to report foreign assets in Schedule FA during that period.

Schedule FA vs. Schedule FSI

Two different schedules:

AspectSchedule FASchedule FSI
ReportsForeign assets heldForeign-source income earned
PeriodCalendar year ending in the financial yearFinancial year
Needed even without income?YesNo — only if there's foreign income
Linked toBlack Money Act penaltiesForeign tax credit and Form 67

What we'll need from you

Account statements
Statements for foreign bank and brokerage accounts for the calendar year.
RSU and ESOP records
Grant, vesting, and sale records from your employer's equity platform.
Investment records
Foreign funds, shares, and other investments.
Property documents
Purchase documents for any foreign property.
Foreign tax documents
Evidence of tax withheld on foreign income.
Exchange rates
Rates for converting values into rupees.

Fees depend on the number and complexity of foreign assets.

How we report foreign assets

Our approach:

  1. 1

    Confirm residency

    We confirm whether you're resident and ordinarily resident for the year.

  2. 2

    List assets

    Every foreign asset and account is listed.

  3. 3

    Gather values

    Peak and closing values, and income, are compiled for the calendar year.

  4. 4

    Prepare Schedule FA

    Assets are reported in the correct tables.

  5. 5

    Report income

    Foreign income goes into Schedule FSI, with Form 67 for credit.

  6. 6

    Review past years

    If assets weren't reported before, we advise on correcting past returns.

If past years weren't reported

Missing disclosures can often be addressed:

Revised returns
A revised return can correct recent years within the time allowed.
Updated returns
An updated return may be possible for older years, within the time limit, with additional tax where income was missed.
Small-holding relief
The penalty relief for foreign assets up to ₹20 lakh (other than immovable property) may apply.
Respond to notices
Respond promptly to any notice about foreign assets, with full records.
Keep records
Keep statements and grant records for future years.
Report every year
Report assets every year while you remain resident and ordinarily resident.

Benefits and responsibilities

Benefits

  • Complete, accurate Schedule FA and FSI
  • RSUs and brokerage accounts reported correctly
  • Foreign tax credit claimed
  • Past gaps addressed before notices
  • Peace of mind on Black Money Act exposure

Responsibilities

  • Tell us about every foreign account and asset
  • Keep statements for the calendar year
  • Share employer equity records
  • Report every year while resident
  • Use the correct ITR form
  • Respond to notices promptly

—FAQ

Questions residents actually ask us

Generally yes. Vested shares held in a foreign brokerage account are foreign assets that residents who are ordinarily resident must report in Schedule FA, whether or not they've been sold.