HNI wealth · Unlisted Equity
Schedule FA disclosure: when foreign company unlisted shares must be reported
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Facts
If you hold shares in a foreign company (including ESOP from a foreign parent) or have invested in an overseas startup, you must report in Schedule FA (Foreign Assets) of your ITR.
Provisions and law
- IT Act, Schedule FA | Black Money Act 2015 | FEMA 1999
Analysis
What to disclose: Country, nature of interest, date of acquisition, cost of acquisition, total investment, income from the foreign asset during the year. Penalty for non-disclosure: ₹10L under Black Money (Undisclosed Foreign Income and Assets) Act 2015. This is mandatory regardless of whether any income was earned. FEMA compliance: Acquiring foreign shares requires RBI permission (generally allowed under LRS, ₹2.5Cr per financial year) or through a recognised route (ESOP, FVCI, etc.).
Conclusion
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Foreign shares, RSU and ESOP sale with Schedule FA
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