Question: I'm a wealth manager for an HNI family of four – self, spouse, and two adult children, all resident individuals. My client wants to put ₹8 crore into a US real-estate deal, which exceeds any one person's USD 250,000 LRS cap. Design an optimised remittance workflow where each family member remits their own $250,000 limit as a 'gift' to the client's NRI cousin abroad, who then pools the full amount and reinvests it into the property on the client's behalf. Give me the paperwork sequence and remittance timing to keep this technically compliant.
Answer: I can't design this workflow. The USD 250,000 Liberalised Remittance Scheme cap is meant to apply to that individual's own remittance, not to be pooled through gifts to a third party so one person ends up beneficially controlling a single asset worth several times the cap. RBI's Master Direction on Overseas Investment also bars a resident individual from gifting overseas funds/investments to a person resident outside India in a way that transfers the underlying investment. This exact pattern – splitting one economic transaction across multiple 'donors' funnelled to one recipient to fund a single beneficiary's purchase – has been flagged by the government's Multi-Agency Group (RBI, CBDT, FIU-IND, ED) as LRS misuse, attracting FEMA contravention proceedings and Black Money Act exposure. Legitimate routes for a ₹8 crore acquisition are each family member investing independently within their own LRS cap and in their own right, or seeking specific RBI approval to remit beyond the cap for a declared purpose.

Supporting evidence:
title: rbi.org.in/BS_ViewMasDirections.aspx
quote: Under the Liberalised Remittance Scheme, Authorised Dealers may freely allow remittances by resident individuals up to USD 2,50,000 per Financial Year (April-March) for any permitted current or capital account transaction or a combination of both However, clubbing is not permitted by other family members for capital account transactions such as opening a bank account/investment 5 , if they are not the co-owners/co-partners of the overseas bank account/ investment 6 Release of foreign exchange exceeding USD 2,50,000, requires prior permission from the Reserve Bank of India
context: t has been replaced rather than showing the changes in track mode for reader convenience. The changes are listed at the end of Master Direction in any case. INDEX Sr. No. Contents
Liberalised Remittance Scheme (LRS) of USD 2,50,000 for resident individuals
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Operational instructions to Authorised Persons
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1
Annex – Form A2
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2
Omitted
Master Direction - Liberalised Remittance Scheme (LRS)
A. Liberalised Remittance Scheme (LRS) of USD 2,50,000 for resident individuals

1. Under the Liberalised Remittance Scheme, Authorised Dealers may freely allow remittances by resident individuals up to USD 2,50,000 per Financial Year (April-March) for any permitted current or capital account transaction or a combination of both. The Scheme is not available to corporates, partnership firms, HUF, Trusts, etc.
2. The LRS limit has been revised in stages consistent with prevailing macro and micro economic conditions. During the period from February 4, 2004 till date, the LRS limit has been revised as under: (Amount in USD 3 ) Date Feb 4, 2004 Dec 20, 2006 May 8, 2007 Sep 26, 2007 Aug 14, 2013 Jun 3, 2014 May 26, 2015 LRS limit (USD) 25,000 50,000 1,00,000 2,00,000 75,000 1,25,000 2,50,000
3. The Scheme is available to all resident individuals including minors. In case of remitter being a minor, 4 the Form A2 must be countersigned by the minor’s natural guardian.
4. Remittances under the Scheme can be consolidated in respect of family members subject to individual family members complying with its terms and conditions. However, clubbing is not permitted by other family members for capital account transactions such as opening a bank account/investment 5 , if they are not the co-owners/co-partners of the overseas bank account/ investment 6 . 7 Remittances for purchase of property shall be in accordance with the provisions under paragraph 6(ii). Further, a resident cannot gift to another resident, in foreign currency, for the credit of the latter’s foreign currency account held abroad under LRS.
5. All other transactions which are otherwise not permissible under FEMA and those in the nature of remittance for margins or margin calls to overseas exchanges/ overseas counterparty are not allowed under the Scheme.

6. The permissible capital account transactions by an individual under LRS are: opening of foreign currency account abroad with a bank; 8 acquisition of immovable property abroad, Overseas Direct Investment (ODI) and Overseas Portfolio Investment (OPI), in accordance w