Schedule FA — Frequently Asked Questions
Quick answers on who must file, which broker CSVs you need, exchange rates, pricing and data handling. For step-by-step filing instructions see How to File.
Who must file Schedule FA?
Only Resident and Ordinarily Resident (ROR) individuals must disclose foreign assets in Schedule FA of ITR-2 / ITR-3. RNOR and NRI taxpayers are exempt. There is no minimum threshold — even one vested RSU share must be disclosed. Full breakdown: ROR vs RNOR vs NRI.
I never sold my RSUs and earned no income — do I still need to file?
Yes. Schedule FA is a disclosure of holdings, not income. Vested RSUs, ESPP shares and the foreign custodial account itself must be reported every year you hold them, even with zero sales and zero dividends. See RSUs in Schedule FA.
Which files do I need from Fidelity, Schwab, E*TRADE, or Morgan Stanley?
Two uploads: Open Lots (per-lot acquisition dates and cost basis) and Transaction History (dividends, sale proceeds, withholding). Add a third file — Closed Lots (Fidelity), Realized Gain/Loss (Schwab), or Gains & Losses (E*TRADE) — only if you sold shares during the calendar year. E*TRADE's files can be CSV or XLSX; no PDFs are needed for any broker. Morgan Stanley StockPlan Connect needs just the Releases and Withdrawals Reports — sold lots are matched automatically. Interactive Brokers is different again: one CSV covers all three slots, and either report works — a custom Activity Flex Query, which must be set to lot-level detail (Open Positions → Lot, Trades → Closed Lots) or it carries no acquisition dates at all, or the annual Activity Statement, which has no such setting and carries none either way, so upload one for every year back to when you first bought what you still hold and the dates are rebuilt from the trade history in them. Export walkthroughs: Fidelity · Schwab · E*TRADE · Morgan Stanley · Interactive Brokers.
Which Charles Schwab interface do you support — Schwab.com or the Equity Award Center?
Both. Transaction History can come from either the Schwab.com brokerage account or the Equity Award Center (EAC) — award-detail sub-rows in EAC exports are handled automatically. Open Lots (Positions → Lot Details) and Realized Gain/Loss exports come from Schwab.com; shares that vested through EAC appear there too, since they sit in the linked brokerage account. Full walkthrough: Schwab export guide.
What if I don't have a Closed Lots CSV?
You only need it if you sold shares during the calendar year. Sold lots still appear in Table A3 with closing value 0 plus the sale proceeds. If you made no sales, Open Lots and Transaction History are enough. Details: when the Closed Lots CSV is needed.
Which exchange rate does Schedule FA use?
The SBI TT Buying Rate (TTBR) on the exact date of each event — acquisition, dividend, or sale — per CBDT's Schedule FA filing instructions. Not the preceding month's rate (that's Income-tax Rule 115, used for computing salary/dividend/capital-gains income, not Schedule FA disclosure). ITRFA.in auto-fetches the correct historical rate for every date. Explainer: SBI TTBR & Rule 115.
Which period does Schedule FA cover — financial year or calendar year?
The calendar year ending December 31, not the Indian financial year. For AY 2026-27 you report holdings for January 1 – December 31, 2025, and the closing balance is the December 31, 2025 value.
Is the preview free? What does it cost?
Uploading and previewing is free — you see Table A2 plus the first rows of Table A3 before paying anything. Unlocking full INR values with the Excel and JSON download costs ₹399 for one filing; CAs can buy a 10-filing pack for ₹2,499. See Pricing.
What happens to my uploaded data?
Files are processed and stored only on India-region servers (Google Cloud, Mumbai) and auto-deleted after 30 days. We never collect your PAN or Aadhaar. Details in the Privacy Policy.
What is the penalty for not filing Schedule FA?
Under the Black Money Act, 2015 the penalty is ₹10 lakh per year of non-disclosure, with a 16-year reassessment window. India already receives your US broker data through FATCA and CRS. More: Black Money Act & Schedule FA.
Is ITRFA.in tax advice?
No. ITRFA.in automates the Schedule FA arithmetic — per-lot INR values, peak and closing balances, correct exchange rates. It is not tax, legal or financial advice; consult a chartered accountant before filing. See About.
Does filling out a W8BEN stop tax being deducted from my US dividends?
No — it reduces the withholding rate under the India-US DTAA (typically to 25%, sometimes lower), it doesn't eliminate it. Tax is still deducted at source; you claim credit for it in India via Form 67 and Foreign Tax Credit.
Do I need Form 67 if I have no dividend income?
Yes, if you're claiming foreign tax credit for any other foreign-taxed income — most commonly US federal tax withheld on an RSU vest or ESPP sale. Form 67 is tied to the credit being claimed, not specifically to dividends. More: Form 67 & FTC.
My RSUs are with a non-US broker, or an account like BOCI holding Alibaba shares — do the same rules apply?
Yes. Schedule FA rules follow the asset — foreign equity held by an ROR — not the specific broker or country. Self-directed accounts are supported too: Interactive Brokers shares, ETFs, mutual funds and bonds in any currency SBI publishes a rate for, with options and futures disclosed in Table D. Some brokers don't offer a CSV export the way Fidelity or Schwab do — Shareworks (Solium) and UBS Financial Services are two we support directly with manual entry or AI-assisted PDF prefill. For any other broker — Ally Invest, Vanguard, Robinhood, Firstrade or anything else — use the any-broker page: enter your holdings and trades there, or upload any statement, trade confirmation, spreadsheet or screenshot for AI-assisted prefill.
I hold foreign shares across two different broker accounts — one Schedule FA or separate filings?
One consolidated Schedule FA, with a separate Table A2 row for each account and Table A3 rows for each account's holdings — not separate filings or separate uploads to the ITR portal.
My employer already included my RSU value in Form 16 — do I still need to report anything else?
Yes. Form 16 covers the income-tax side (perquisite value at vest). Schedule FA is a separate asset-disclosure obligation that applies every year you hold the shares, and any later sale still needs to be reported as a capital gain in Schedule CG. See why "already taxed" doesn't cover disclosure.
How does the Income Tax Department actually find out if I didn't declare a foreign asset?
Through automatic exchange of financial account information between countries — FATCA (with the US) and CRS (with 100+ other countries) — so your foreign broker already reports your holdings to Indian tax authorities. A mismatch between what you disclosed and what your broker reported is what typically triggers scrutiny.
Where do I find the FMV my company uses for RSU vesting?
Usually your broker's vesting confirmation or release statement states the fair market value used on the vest date. If unavailable, the closing stock price on the vest date (or the nearest preceding trading day) is the standard fallback.
When does the 24-month long-term holding period for RSU shares start counting?
From the vest date — when you acquired the shares — not the grant date. Foreign company shares are treated as unlisted securities for Indian capital gains purposes, requiring 24 months of holding for long-term treatment. See capital gains on RSU sales.
Is transferring RSU shares between custody or stock-plan accounts itself a taxable event?
No. Moving shares between accounts, by itself, does not create Indian tax liability — there is no sale. Report the shares in Schedule FA against whichever account actually holds them on the reporting date.
How accurate is the automatic Client Statement PDF reading?
Every PDF is read twice independently and cross-checked before a number is shown. If the two readings disagree on a figure, that field is left blank with a note to enter it yourself, rather than risk showing a wrong number confidently. Fields marked "Auto-filled from your Client Statement PDF" on the review page passed this check — always compare them against your own statement before finalizing.
I hold RSUs/ESPP through a US broker and also invest directly through a platform like INDmoney — how do I file one Schedule FA?
Schedule FA must disclose every foreign asset you held during the year, from every source — not just your employer's stock plan. Platforms like INDmoney typically provide their own Schedule FA / FSI-formatted sheets for direct holdings, which you can use as-is for those rows. ITRFA.in currently generates entries from Interactive Brokers, Fidelity, Schwab, E*TRADE and Morgan Stanley exports; for other platforms, add their holdings as additional Table A2/A3 rows in the same Schedule FA — one consolidated schedule with multiple entries, not separate filings.
Do I need to report cryptocurrency in Schedule FA?
No. Schedule FA discloses foreign assets tied to a specific overseas jurisdiction — a foreign bank account, brokerage account, or equity holding. Cryptocurrency held through an exchange isn't tied to a foreign country the same way, and there's no dedicated Schedule FA field for it under current rules. It has its own separate reporting (Schedule VDA for any transfer, plus disclosure under the Income Tax Act) — distinct from foreign asset disclosure.
What's the penalty if I don't repatriate or reinvest RSU sale proceeds within 180 days?
This is a separate FEMA penalty, not the Black Money Act one. Under Section 13(1) of FEMA, 1999, the penalty can go up to three times the amount involved where that amount is quantifiable, or up to ₹2 lakh where it isn't, plus ₹5,000 per day for a continuing contravention after adjudication. This is in addition to — not instead of — the disclosure penalties for not reporting the holding itself in Schedule FA.
I already paid tax on my RSU vest through sell-to-cover — do I also need to claim FTC or file Schedule FSI for it?
Usually no separate claim needed. For most employers, the perquisite value already reflects the sell-to-cover deduction as a single amount — there's no separate foreign tax paid to credit. A second FTC/FSI claim only applies if your employer genuinely withholds tax twice on the same vest (uncommon, but it happens with some payroll setups), or if you're claiming FTC for something else entirely, like dividend withholding. Note that the sell-to-cover sale itself can still create a small separate capital gain or loss, reported in Schedule CG — that's unrelated to FTC.
I forgot to claim foreign tax credit last year — can I claim it in this year's return instead?
No. Foreign tax credit must be claimed for the year the foreign tax was actually paid or withheld, via that year's Form 67 and return. It cannot be carried forward and claimed against a later year's Indian tax. If you missed it, the usual path is a rectification or revised return for that specific year, where still open — talk to a chartered accountant about your options.