Foreign-asset disclosure (Schedule FA) checklist

Once you are Ordinarily Resident in India, you must disclose every foreign asset in Schedule FA, even ones that earned nothing, because the Black Money Act penalises the asset itself (Rs 10 lakh a year), not just income. This checklist walks the asset categories, bank accounts, shares, ESOP/RSU, pensions, property and trusts, so nothing is overlooked, and notes the Foreign Tax Credit and the small-holding relaxation.

Last reviewed: 29 May 2026

Guidance, not advice. We explain the rules, we don't assess your situation. Always seek financial or tax advice from your accountant, or contact Income Tax Department. Read our editorial scope →

What it contains

A category-by-category Schedule FA checklist, plus the Foreign Tax Credit (Form 67) and Rs 20 lakh relaxation reminders.

How to use it

Confirm you are Ordinarily Resident

Schedule FA is mandatory for Ordinarily Residents; NR and RNOR are generally outside it (though RNOR should disclose conservatively for high-risk legacy assets).

Walk every category, including nil-income

Go through each category and list even dormant or zero-balance accounts and unvested RSUs, the penalty is for the asset, not just income.

Claim the Foreign Tax Credit

Where foreign tax was paid on income also taxed in India, file Form 67 by the end of the assessment year so you are not taxed twice.

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SCHEDULE FA - FOREIGN-ASSET DISCLOSURE CHECKLIST (Ordinarily Residents)

  AM I IN SCOPE?
  [ ] I am Ordinarily Resident (not NR / not RNOR) for the year -> Schedule FA is MANDATORY
  [ ] Report assets held at ANY time in the CALENDAR year (1 Jan - 31 Dec), even if they earned nothing

  WALK THE CATEGORIES (list each, with country / institution / peak + closing balance in FCY + INR / income / offered-to-tax):
  [ ] Foreign bank and custodial accounts (including crypto-exchange accounts) - even zero-balance / dormant ones
  [ ] Foreign equity and debt (shares, bonds, brokerage holdings)
  [ ] ESOP / RSU / ESPP - vested AND unvested (a financial interest)
  [ ] Foreign pensions / retirement accounts (401(k), Roth IRA, superannuation)
  [ ] Foreign immovable property
  [ ] Signing authority on any foreign account (even if not the owner)
  [ ] Foreign trusts (settlor / beneficiary / trustee)
  [ ] Any other foreign income or asset

  DOUBLE-TAX RELIEF:
  [ ] Foreign tax paid on income also taxed in India? -> claim the Foreign Tax Credit on Form 67 (by the END of the assessment year), reconcile with the FSI and TR schedules

  REMEMBER:
  [ ] Disclosure is NOT the same as taxability - you may owe no extra tax but must still report
  [ ] Small-holding relaxation: no penalty if aggregate non-immovable foreign assets are under Rs 20 lakh - but you STILL disclose
  [ ] The Black Money Act penalises the ASSET (Rs 10 lakh/year), and FATCA/CRS means foreign accounts are visible