If you work for a multinational and hold vested RSUs or ESPP stock, everything Schedule FA needs is already in your equity-platform statements. The problem is that the statements are built for a US tax year and Schedule FA is built for an Indian form — so the mapping is not obvious, and a wrong period or a missed account is where things go wrong.
This walks through where each figure comes from. The examples are illustrative, not from any client file.
Before anything: the period trap
Schedule FA is not reported for the Indian financial year. It is reported for the relevant accounting period of the foreign entity — which, for the US and most other countries, is the calendar year.
So while the rest of your return covers 1 April to 31 March, your Schedule FA figures come from a January–December window. Pulling "FY" numbers straight off a statement and dropping them into Schedule FA is the most common error we see on MNC returns, and it is entirely avoidable.
The statements you need
From your platform (E*TRADE, Morgan Stanley at Work, Fidelity, Schwab — the layout differs, the content doesn't), download:
- Vesting / release report — every vest event, date, share count, and fair market value
- Dividend statement — gross dividends and foreign tax withheld
- Form 1042-S — the US statement of income paid to a foreign person and tax withheld
- Trade / realised gain-loss report — sales, dates, proceeds, cost basis
- Account statement / holdings summary — the account details and period values
Mapping each figure
1. The account itself. Your brokerage account is a foreign account and gets reported: the institution's name and address, the account number, the date opened, the peak value during the period, and the closing balance. The peak value is not the year-end value — read it off the period statements, not the December snapshot.
2. The equity holdings. For each foreign share holding you report the entity's name and address, the date of acquisition (for RSUs, this is the vesting date, not the grant date), the initial value (the FMV at vesting — the same figure that was already taxed as a salary perquisite), the peak value during the period, and the closing value.
The vesting-date FMV does double duty: it is the perquisite already in your Form 16 (Form 130 from FY 2026-27), and it becomes your cost of acquisition when you eventually sell. Take it from the vesting report, not from a re-estimate.
3. Income from the holding. Dividends received during the period, and the tax withheld abroad on them. Both are on the dividend statement and on Form 1042-S. This same pair feeds your Form 67 foreign tax credit claim — see how Form 67 actually works.
4. Proceeds from sale. If you sold during the period, the sale proceeds are reported too. Note that the capital-gains computation is a separate schedule — Schedule FA is disclosure, not tax calculation, and the two use different periods.
Where people get caught
- Reporting only what you sold. Schedule FA is about holdings. If you hold vested shares and sold nothing, you still report.
- Using the year-end value as the peak value. They are different fields for a reason.
- Forgetting the account. People report the shares and forget the brokerage account is itself a reportable foreign account.
- Using the grant date instead of the vest date as the date of acquisition.
- Mixing periods — the FY/calendar-year trap above.
- Filing ITR-1. Once Schedule FA applies, ITR-1 is not available.
Why the precision matters
Schedule FA sits under the Black Money (Undisclosed Foreign Income and Assets) Act, not just the Income-tax Act. Non-disclosure of a foreign asset can attract a penalty of ₹10 lakh per year of default and possible prosecution, independent of any tax due. (Foreign assets other than immovable property below ₹20 lakh are now outside that exposure — but disclosure remains the correct course.)
That asymmetry is the point: the tax on a few vested shares might be modest, while the cost of omitting them is not proportionate to it. Schedule FA is worth doing carefully, once, properly.
For the full picture of how vesting, dividends and sale are each taxed, see RSU, ESOP and foreign stock taxation for resident employees.