NRI Wealth Advisory

NRI Banking Account Structure

LRS — Liberalised Remittance Scheme

NRI Indian Investment Access

• Equity (listed): NRI can invest on repatriation basis (PIS route) or non-repatriation basis; 5% single-scrip limit in a listed company for NRIs under SEBI portfolio rules
• Mutual Funds: NRI can invest with most AMCs using NRE/NRO accounts; US and Canada-resident NRIs face restrictions due to FATCA/PFIC rules — select AMCs only
• PMS: NRI can invest in Portfolio Management Services on non-repatriation basis; Form 15CA/15CB required on income repatriation; SEBI RIA/PMS manager handles investment but CA handles the tax layer
• AIF (Category I/II): NRI investment permitted under FEMA; Category II AIF income is pass-through (Section 115UB) taxed at NRI's hands; DTAA may apply to reduce the rate
• AIF (Category III): Taxed at the fund level (30% surcharge inclusive) — NRI investors receive post-tax distributions; Form 64D from the AIF is required for ITR reporting
• Real estate: FEMA (NDI) Rules 2019 — NRI/OCI can buy residential and commercial property; agricultural land, plantation property, and farmhouse are restricted (RBI approval required)

Schedule FA — Foreign Asset Disclosure

• Mandatory for any Resident Indian (RNOR or ROR) who holds foreign assets at any point during the financial year
• Covers: foreign bank accounts, equity in foreign companies (including unvested RSUs), foreign insurance policies, immovable property abroad, and other foreign assets
• Filed as part of ITR — Schedule FA; non-disclosure even of small accounts is a compliance risk
• Penalty for non-disclosure: Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 — penalty up to ₹10 lakh per asset, plus prosecution
• NRIs do not file Schedule FA for offshore assets held during NRI years — but RNOR and Resident individuals returning from NRI status must disclose from the first year of Indian residency
• Planning point: the transition year (when you first become RNOR) is the year to audit all foreign holdings and determine disclosure obligations

What We Do

• Section 6 residency determination — are you NRI, RNOR, or Resident this year? The answer changes your entire tax and disclosure position
• NRO/NRE/FCNR account strategy — which account type is right for each income stream, and what the repatriation path looks like
• Repatriation advisory — USD 1M annual cap management, Form 15CA/15CB CA certificate for NRO repatriation, Form A2 compliance
• LRS planning — how much to remit, TCS implications (Section 206C(1G)), and investment vehicle selection for offshore deployment
• PMS/AIF investment structuring — tax treatment on income and exit, DTAA applicability, Form 64C/64D from the AIF, ITR reporting
• ITR filing with Schedule FA — for returning NRIs in RNOR years who now hold global income and offshore assets
• FEMA compliance for NRI investment in Indian equity, property, and AIFs — PIS registration, FEMA (NDI) reporting
• Transition year planning — the year you return to India permanently: RNOR status utilisation, NRE account redesignation to RFC, offshore portfolio review before ROR status triggers global taxation