Schedule FA for AY 2027-28: Filing Guide for FA Disclosure in ITR

What is Schedule FA (Foreign Assets)?

• Schedule FA (Foreign Assets) is a mandatory disclosure schedule in the ITR for residents who hold foreign assets, foreign bank accounts, overseas investments, or earn foreign income.
• Foreign assets are reported on a calendar-year basis. And For AY 2027-28, disclosures relate to assets held during Calendar Year 2025 (1 January 2025 to 31 December 2025).

Schedule FA (Foreign Assets) Filing Checklist

Following lists four important compliance requirements for Schedule FA (Foreign Assets) discloser :

1. Disclose all foreign assets: Report foreign assets held at any time during Calendar Year 2025. Examples: Foreign shares, Overseas bank accounts, Foreign mutual funds, Foreign Employee Stock Ownership Plan or Employee Stock Option Plan, Overseas properties
2. Convert values using SBI TT Buying Rate: All foreign currency values must be converted into INR using the State Bank of India Telegraphic Transfer (TT) Buying Rate applicable on the relevant date.
3. Report acquisition separately : Acquisition details should be reported and not merely the year-end balance.
4. Report income separately: Income such as Dividends, Interest and Capital gains must be declared both In Schedule FA (Foreign Assets), and Under the relevant income heads in the Income Tax Return. Following Example uses a hypothetical U.S. brokerage account containing three stocks:

Asset	Purchase Cost	Highest Value in 2025	Balance on 31 Dec 2025	Income
XYZ Inc.	$1,000	$1,300	$1,150	Dividend $20
ABC ETF	$3,000	$3,350	$3,300	Nil
MNC Inc. (sold)	$3,000	$5,500	Sold	Profit $2,300

The example demonstrates that even if an asset is sold during the year, its details and sale proceeds must still be disclosed in Schedule FA (Foreign Assets).

Table A3 – Foreign Equity and Debt Interests

Above table will have to show how foreign shares are reported. Required disclosures include:

For each foreign security Country, Name of entity, Date of acquisition, Initial value, Peak value during the year, Closing value, Dividend/interest income and Gross sale proceeds. Example entries shown:

XYZ Inc.

• Country: US
• Date acquired: 15 March 2025
• Initial value: INR 86,550
• Peak value: INR 1,15,700
• Closing value: INR 1,02,891
• Dividend: INR 1,759

ABC ETF

• Country: US
• Date acquired: 1 July 2025
• Initial value: INR 2,55,600
• Peak value: INR 2,95,805
• Closing value: INR 2,95,251

MNC Inc. (Sold)

• Country: US
• Date acquired: 3 September 2023
• Initial value: INR 2,46,840
• Peak value: INR 4,67,500
• Closing value: Nil
• Sale proceeds: INR 4,76,298

Table A2 – Foreign Custodial Accounts

Following explains reporting of overseas brokerage/custodial accounts. Details required Account number, opening balance, Peak balance during the year, Closing balance, Gross interest credited and Dividend-sale proceeds credited. Example shown:

Particulars	Amount
Opening Balance	INR 79,005
Peak Balance	INR 3,89,142
Closing Balance	INR 3,89,142
Gross Interest	INR 4,69,687

Specifically notes that dividend and sale proceeds credited to the account should also be disclosed.

Important Compliance Takeaways

• Schedule FA (Foreign Assets) is applicable only to specified resident taxpayers.
• Reporting is based on calendar year, not the financial year.
• Foreign shares, ETFs, brokerage accounts and other overseas assets must be disclosed.
• Sale proceeds, dividends and interest must be separately reported.
• SBI TT Buying Rate should be used for conversion into INR.
• Non-disclosure or incorrect disclosure of foreign assets can attract severe consequences under the Income-tax Act and, where applicable, the Black Money (Undisclosed Foreign Income and Assets) Act.

While filing AY 2027-28 returns, ask clients specifically about the following:

• Foreign brokerage accounts (Interactive Brokers, Charles Schwab, Fidelity, etc.). US stocks and ETFs, Foreign ESOPs/RSUs, Overseas bank accounts, Foreign dividends and interest and Assets sold during Calendar Year 2025
• Many taxpayers report foreign income but inadvertently miss Schedule FA (Foreign Assets) disclosures, which can trigger notices despite proper tax payment.