CA K Sanjay BhargavChartered Accountant
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Schedule FA when your shares are on Fidelity, Schwab or Morgan Stanley

CA K Sanjay Bhargav, Chartered Accountant, Bengaluru

Membership No. 250054 · DISA (ICAI)

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Short answer: the platform does not change what Schedule FA needs. Fidelity, Schwab, Morgan Stanley at Work and E*TRADE all hold the same five figures under different report names. What decides whether the disclosure is right is the period you pull them for, and three errors that have nothing to do with which platform you use.

The E*TRADE walkthrough is here. This is the version for everyone else.

Before anything: the period

Schedule FA is reported for the calendar year — 1 January to 31 December — because that is the accounting period of the foreign entity. The rest of your return runs 1 April to 31 March.

Every report below should be pulled for the calendar year. Getting this wrong is the most common error on MNC returns, and it invalidates every figure that follows it.

The five reports, whatever they are called

Platforms use their own names, and those names change. What you are looking for is:

What you needWhat it gives you
Vesting / release reportEvery vest event: date, share count, fair market value at vest
Dividend statementGross dividends, and tax withheld abroad
Form 1042-SThe US statement of income paid to a foreign person, and tax withheld
Realised gain-loss reportSales: dates, proceeds, cost basis — only if you sold
Account / holdings statementAccount details, and the period values the peak is read from

If a report is not obvious in the interface, the plan administrator or your employer's stock plan team can produce it. That route is usually faster than hunting, and it is the only route once an account has been closed or migrated.

What Schedule FA actually asks for

Four blocks, and the reports above fill all of them:

  • The account itself — institution name and address, account number, date opened, peak value during the period, closing balance.
  • Each holding — entity name and address, date of acquisition, initial value, peak value, closing value.
  • Income — gross dividends, and tax withheld abroad.
  • Sale proceeds, where you sold during the period.

The three errors, on every platform

Grant date instead of vest date. The date of acquisition is the date the shares vested and became yours — not the date they were granted. Every platform shows both, usually adjacent, and they are easy to transpose. The initial value follows the same rule: it is the fair market value at vesting, the figure already taxed as a salary perquisite, and it later becomes your cost of acquisition when you sell.

Year-end value instead of peak value. They are separate fields for a reason. The peak is the highest value during the period, read off the period statements — not the 31 December snapshot. If your peak and closing figures are identical on every line, the working is wrong.

Reporting the shares and forgetting the account. The brokerage account is itself a reportable foreign account, with its own peak and closing balance. Disclosing the holdings and omitting the account is a very common omission and an entirely avoidable one.

The worksheet

The peak value is the figure that takes the time, because it has to be assembled from month-end statements rather than read off a single page. The worksheet below does that working — enter the month-end values and it computes the peak and the closing figure for the account and for each holding, alongside the account and holdings tables and a pre-filing checklist.

If a year was missed

The exposure sits under the Black Money Act, not only the Income-tax Act, and it is not proportionate to the tax involved — which is precisely why it is worth dealing with rather than leaving.

It is also not permanent. For a recent year, the revised return window may still be open — see missed Schedule FA. For years further back, FAST-DS 2026 runs until 31 December 2026 and settles undisclosed foreign holdings on materially better terms than the Black Money Act charges.

What does not work is starting to disclose from the current year and leaving the earlier ones unaddressed.

The credit that runs alongside

Where tax was withheld on your dividends, that is claimed separately — not in the return itself, and on a different period basis. See claiming foreign tax credit, which also covers the change from Form 67 to Form 44.

This is a working reference. Platform report names change; what does not change is the period, the fields, and the three errors above.

Download the Schedule FA peak balance worksheet

The month-by-month working that computes peak value for you, the account and holdings tables with the source for every field, and a pre-filing checklist. CSV — opens in Excel or Google Sheets.

Your number is used to answer questions on the worksheet and on foreign asset reporting. No third-party sharing, and you can ask to be removed at any time.

Frequently asked questions

Does it matter which platform holds the shares?

Not to the schedule. Fidelity, Schwab, Morgan Stanley at Work, E*TRADE — Schedule FA asks for the same fields whichever one it is: the account, each holding, the income, and any sale proceeds. What differs between platforms is only what they call their reports and where those sit in the interface. The figures, and the errors people make with them, are identical.

Which reports do I need?

Five, under whatever name your platform uses for them: the vesting or release report, showing every vest with its date, share count and fair market value; the dividend statement; Form 1042-S; the realised gain-loss report if you sold anything; and an account or holdings statement covering the whole period. If you cannot find one, the plan administrator or your employer's stock plan team can produce it.

What period do I download for?

The calendar year — January to December — not the Indian financial year. Schedule FA follows the accounting period of the foreign entity, and for the US and most other countries that is the calendar year. Pulling April-to-March figures is the most common error on MNC returns, and it makes every number that follows wrong.

I did not sell anything. Do I still report?

Yes. Schedule FA is a disclosure of holdings, not a computation of gains. Vested shares you still hold are reportable in a year with no transaction at all — and so is the brokerage account itself, which people report the shares and then forget.

My employer moved the plan to a different platform mid-year. What then?

Both accounts existed during the period, so both need to be considered, with the peak of each taken over the part of the year it was held. The practical risk is losing access: a migration usually closes the old account, and historical statements become harder to obtain once it does. Ask the plan administrator for the closing statements before access lapses rather than after.

I have shares on a platform I can no longer log into. What do I do?

Ask the plan administrator or your employer's stock plan team for a historical statement — they can generally produce one for a closed or migrated account. Reconstructing from payslips is a last resort and a materially weaker record if the disclosure is ever questioned.

What happens if an earlier year was missed?

Schedule FA sits under the Black Money Act, not only the Income-tax Act, and the exposure is not proportionate to the tax involved. It is also not permanent: a revised return may still be open for a recent year, and for years further back the FAST-DS window runs until 31 December 2026. The wrong response is to quietly start disclosing from this year and hope the earlier ones are not noticed.

Statements in hand and unsure what goes where?

Send the vesting report and the account statement for the calendar year. The Schedule FA entries are mapped from them, and any earlier year that was missed is flagged before it becomes the more expensive problem.

Related service: Foreign Income / RSU & ESOP