If you work for a multinational and receive RSUs, or you've bought US shares through an overseas broker, your income tax return has an extra job. As well as paying tax on the income, you have to disclose the assets in Schedule FA (Foreign Assets).
The most common mistake isn't forgetting the schedule altogether. It's using the wrong period. Your income runs on India's April–March year, but Schedule FA asks about the calendar year, January to December. Mixing the two up is how assets go missing from a return.
This guide explains who has to file Schedule FA, what period it covers, what RSU holders usually report, and how to correct a return that left something out.
Note: This is general information, not tax advice. Rules and thresholds change and depend on your residential status and facts, so verify everything here with a CA before filing.
Who has to fill in Schedule FA?
Residents of India must disclose every foreign asset or account where they are the legal owner, beneficial owner or beneficiary. That includes foreign bank accounts, brokerage (custodial) accounts, shares and other securities, property, insurance with a cash value, interests in foreign entities, and accounts you can sign on.
You don't need to fill in Schedule FA if you are "not ordinarily resident" (RNOR) or non-resident for the year. That's why your residential status is the first thing to settle.
You have to report the assets even if they earned nothing, you sold nothing, or your income is below the taxable limit. Schedule FA is a disclosure, not a tax calculation.
Which form? ITR-1 and ITR-4 don't have Schedule FA. If you have foreign assets or foreign income, you'll usually file ITR-2, or ITR-3 if you have business or professional income.
The calendar-year rule
Schedule FA covers assets held at any time during the calendar year ending 31 December that falls within the financial year of the return.
| Return | Income period (FY) | Schedule FA period (CY) |
|---|---|---|
| AY 2026-27 (filed in 2026) | 1 Apr 2025 – 31 Mar 2026 | 1 Jan 2025 – 31 Dec 2025 |
| Tax year 2026-27 (to be filed in 2027) | 1 Apr 2026 – 31 Mar 2027 | Check the period on the new form when it's notified |
From tax year 2026-27, returns are filed under the Income-tax Act, 2025. The Income Tax Department has said the new ITR forms under the Income-tax Rules, 2026 will be notified before the due dates. Until then, the reporting period for foreign assets under the new forms isn't confirmed, so check the period printed on the notified form, or ask your CA.
What this means for RSU holders:
- RSUs that vested in February 2026 count as salary in FY 2025-26, the return you filed in 2026. But the shares were acquired in calendar 2026, so under the current calendar-year rule they fall outside this return's Schedule FA and would be disclosed in a later return. Confirm the period with your CA once the new forms are out.
- Shares you held at any point in 2025 and sold in, say, October 2025 still go in the AY 2026-27 Schedule FA. They show a closing value of zero and the sale proceeds.
- A dividend paid in February 2026 is income for FY 2025-26, but it falls outside the CY 2025 window for Schedule FA. Income and disclosure follow different calendars, and that's by design.
What RSU holders usually report
When RSUs vest, the fair market value of the shares is taxed as a salary perquisite. It normally shows up in your Form 16. That taxed value also becomes your cost if you later sell. Once the shares land in your overseas brokerage account, they're foreign assets.
The tables that matter most for RSU holders:
| Table | What goes in it | Typical RSU/US-share example |
|---|---|---|
| A1 Foreign depository (bank) accounts | Peak balance, closing balance, interest | A US bank account that receives sale proceeds |
| A2 Foreign custodial accounts | Peak balance, closing balance, gross amounts paid or credited | Your account at the plan's broker, or another overseas broker |
| A3 Foreign equity and debt interest | Initial value, peak value, closing value, income, sale proceeds | The vested shares themselves |
| C Immovable property outside India | Cost, income | A flat abroad |
| D Other capital assets outside India | Cost, income | For example, crypto held abroad |
Tables A4, B, E, F and G cover cash-value insurance, financial interests in entities, signing authority, foreign trusts and other income.
Unvested RSUs are generally not treated as assets yet, but follow your CA's view.
Converting to rupees
Peak balances, investment values and closing values are converted at the SBI telegraphic transfer (TT) buying rate on the relevant date:
- the date of the peak, for peak values;
- the date of investment, for initial values;
- 31 December, for closing values.
Foreign income, such as dividends and sale proceeds, follows the separate conversion rules for income.
Peak value is the part that takes the most work. For shares bought in many lots, you need each lot's highest value in rupees during the year. That means daily prices multiplied by the TT rate for that day. Doing it in a spreadsheet takes a long time.
Why it matters: penalties
Not disclosing a foreign asset, or giving inaccurate details, can attract a ₹10 lakh penalty under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015. This applies to residents other than RNORs.
Since 1 October 2024, the Finance (No. 2) Act, 2024 says that penalty doesn't apply where the aggregate value of assets other than immovable property doesn't exceed ₹20 lakh. Before that, the exemption covered only bank balances up to ₹5 lakh. In August 2025 the CBDT also said prosecution won't be started in cases covered by this exemption. Thresholds can change, so check the current limit with your CA.
Don't rely on the threshold to skip disclosure. Schedule FA is still mandatory. The Income Tax Department also runs awareness campaigns that remind residents with foreign holdings to fill it in.
Foreign tax already withheld, for example on US dividends, is claimed separately through Form 67 and Schedules FSI and TR.
Missed something in your 2026 return? You can still fix it
For AY 2026-27, the return covering FY 2025-26 and CY 2025 foreign assets:
- Didn't file at all? A belated return can be filed by 31 December 2026, or before your assessment is completed if that's earlier. A late fee of ₹1,000 or ₹5,000 applies, depending on income.
- Filed, but left out Schedule FA or reported it wrongly? Under the Finance Act, 2026, a revised return can be filed until the end of the assessment year, which is 31 March 2027 for AY 2026-27, or before your assessment is completed if that's earlier. A fee under section 234-I can apply to revisions filed late in the window, so ask your CA.
The sooner you correct it, the better.
A year-round checklist for RSU and US-share holders
- Confirm your residential status for the year (resident, RNOR or non-resident).
- Keep every broker statement for the calendar year. You need the vest confirmations, the sale confirmations and the 31 December holdings.
- Keep a record of every lot: date, quantity and cost. Schedule FA's A3 table works lot by lot.
- Track peaks as you go. Calendar 2026's peaks are being set now, before 31 December.
- Reconcile the two calendars. Map the FY income (salary perquisite, dividends, gains) separately from the CY assets.
- Hand your CA one clean file, not a folder of PDFs.
How Agni Folio helps
Agni Folio keeps your US shares, RSU lots and foreign bank balances alongside your Indian portfolio, each in its own currency. You can switch your view between rupees and dollars.
The Schedule FA report (Premium) fills tables A1, A2, A3, C and D for the calendar year from the holdings you already track:
- A3 lots: one row per purchase lot. Lots sold during the year show a zero closing value and the sale proceeds.
- Rupee values: converted at SBI TT buying rates, with every figure showing the amount, the rate and the date.
- "Not filled": anything it can't place is listed here so you can enter it yourself.
- Per person: worked out for one family member at a time.
- Excel export for your CA.
Read exactly how the numbers are worked out in the Indian tax reports guide.
Accuracy depends on recording buys and sells, not just today's value. Upload broker statements and contract notes on the AI Import page, check the rows AI reads, and save. Statements your bank or broker already emails you can come in by email too: forward them to your personal Agni Folio address, by hand or with a Gmail, Outlook or iCloud rule. PDF, CSV and Excel attachments are read into holdings and transactions and wait on AI Import until you review and confirm them. It works on the free plan. See how email import works. Prefer not to share statements? Enter holdings manually; we never ask for bank, broker or email logins.
Track your foreign assets free
Agni Folio helps people track and plan their money. It doesn't give financial or tax advice, make trades or hold anyone's assets. This article is general information, not tax advice.
