Got RSUs from your US employer? Bought a few shares of Apple or Tesla through an app like Vested or IND money? If yes, there's one part of your tax return you cannot afford to skip — Schedule FA.
What is Schedule FA?
Schedule FA (Foreign Assets) is a section in
your Income Tax Return where you declare any foreign assets you held during the
year — foreign bank accounts, foreign shares, mutual funds, RSUs, ESOPs, even a
signing authority on someone else's foreign account.
It's not optional, and it's not the same as
reporting your capital gains. Even if you haven't sold a single share, if you held
foreign assets during the year, you must report them.
Who Needs to File It?
Per the Income Tax Department's own guidance,
if you're a Resident and Ordinarily Resident in India, you must disclose
every foreign asset or account in which you're a legal owner, beneficial
owner, or beneficiary — held at any point during the relevant calendar
year. This covers:
●
Salaried employees with US RSUs or ESOPs
●
Anyone who bought international stocks (Apple,
Google, Tesla, etc.)
●
People with a foreign bank account, even a
dormant one
●
Freelancers with balances held abroad
●
Returning NRIs with an overseas pension fund
●
Anyone with signing authority on someone
else's foreign account
Schedule FA does not need to be filled
if you're classified as “not ordinarily resident” or “non-resident.”
One important catch: Schedule FA is
available only in ITR-2, ITR-3, ITR-5, ITR-6, and ITR-7. The Income Tax
Department has explicitly clarified that if you hold foreign assets, you should
not file ITR-1 or ITR-4 — these forms simply don't have the schedule.
The Calendar Year Trap
This is where most people go wrong.
Your regular income tax return follows India's
financial year — April to March. But Schedule FA runs on the calendar year —
January to December.
So, for your return for AY 2026-27 (income
earned in FY 2025-26), you're not reporting foreign assets held between April
2025 and March 2026. You're reporting assets held between 1 January 2025 and
31 December 2025.
Example: You bought US shares in November 2025 and bought more in February
2026. For this year's Schedule FA, only the November 2025 holding matters — the
February 2026 purchase gets reported next year.
Mark your calendar (literally) for this one —
it trips up even experienced filers.
Is There a Minimum Value Below
Which I Can Skip This?
Short answer: generally, no.
There is no minimum threshold that lets you
skip the disclosure itself. Even a small balance in a foreign bank
account or a few dollars' worth of stock technically needs to be reported.
There is some relief, though. As per the Union
Budget 2026-27 presented in Parliament, non-disclosure of non-immovable
foreign assets (i.e., excluding property) with an aggregate value less than
₹20 lakh will get immunity from prosecution, applied retrospectively from 1
October 2024. But this only protects you from the harshest consequence — it
does not remove your obligation to disclose.
What Happens If You Don't Report
It?
This is the part that genuinely surprises
people. The Income Tax Department's own portal confirms that failure to report
foreign assets and income can attract assessment, penalties up to ₹10 lakh,
and prosecution under the Black Money (Undisclosed Foreign Income and
Assets) and Imposition of Tax Act, 2015 — and this applies even if you
didn't owe any extra tax.
And here's the thing — the tax department
already knows. Under the Common Reporting Standard (CRS) and the US FATCA
framework, India receives detailed data every year on foreign accounts held by
its residents — account balances, interest, dividends, and sale proceeds —
directly from foreign financial institutions. This is confirmed on the Income
Tax Department's own portal. So “I forgot” rarely works as a defence anymore.
What You Need to Report
Schedule FA has separate tables (A1 to G)
depending on the type of asset — foreign bank accounts, foreign equity/debt,
insurance contracts, immovable property, and more. For something like US
shares, you'd typically report:
●
The initial value and peak value
during the calendar year
●
The closing value as on 31 December
●
Any dividend or interest credited
during the year
●
Proceeds from any sale or redemption
All figures must be converted to Indian rupees
using the State Bank of India's telegraphic transfer buying rate on the
relevant date, as per the Income Tax Department's official guidance.
Keeping a simple running log of your foreign
holdings through the year — rather than digging it all up at filing time —
saves a lot of last-minute stress.
Made a Mistake or Missed It Last
Year?
The Income Tax Department itself confirms that
if you missed reporting foreign assets in an earlier return, you can file a
revised return to correct it — but you must use a form that includes
Schedule FA (not ITR-1 or ITR-4). It's a straightforward fix if caught in time,
which is exactly why it's worth reviewing your last return now rather than
waiting for a notice.
The Bottom Line
Schedule FA isn't complicated once you know
the rules — but the two things that catch people out are the calendar-year
reporting period and the assumption that small holdings don't count.
Both assumptions can be expensive.
If you hold any foreign shares, RSUs, or
accounts — even modest ones — it's worth having a quick conversation with your
CA before filing, rather than after receiving a notice.