Schedule FA is the foreign asset disclosure in ITR-2 and ITR-3. For Indian residents holding RSUs in US companies through brokers like Fidelity, Morgan Stanley or Schwab, Schedule FA is mandatory — regardless of the value of the holding and regardless of whether any income was earned. Omitting a single foreign asset attracts a flat penalty of Rs. 10 lakh under Section 41 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015.
This is the most commonly missed detail. Schedule FA covers the period from 1 January to 31 December — the calendar year — not the Indian financial year (April to March). When filing ITR for FY 2024-25 (April 2024 to March 2025), the Schedule FA disclosure covers the calendar year 2024 (January to December 2024).
This means RSU lots acquired in Q1 of the financial year (April to June 2024) belong to the previous calendar year's Schedule FA. And RSU lots acquired in Q4 of the calendar year (October to December 2024) belong to the current year's Schedule FA even though the financial year has not ended.
Table A2 covers the foreign brokerage account itself — the account where your RSUs are held. For each account, you must disclose:
| Field | What to enter |
|---|---|
| Country name and code | United States of America / US |
| Name of institution | Fidelity NetBenefits / Charles Schwab / Morgan Stanley etc. |
| Account number | As shown on your broker statement |
| Date of opening | Date the brokerage account was opened |
| Peak balance during the year | Highest total account value during Jan 1 to Dec 31, in USD and INR |
| Closing balance | Account value on December 31, in USD and INR |
| Gross interest credited | Any interest earned on cash balance, in USD and INR |
All INR conversions use the SBI TT Buy rate applicable on December 31 of the calendar year for closing balance, and the rate on the date when the peak occurred for peak balance.
Table A3 requires a separate entry for each equity holding. For RSU holders, this typically means one row per company whose shares you hold. For each holding:
| Field | What to enter |
|---|---|
| Name of entity | Company name (e.g., Alphabet Inc., Microsoft Corporation) |
| Country | United States of America |
| Date of acquiring interest | Date of the first vest in the calendar year |
| Initial value of investment | FMV on the acquisition date, in INR at Rule 115 rate |
| Peak value during the year | Highest value the holding reached during Jan 1 to Dec 31, in INR |
| Closing value | Value of the holding on December 31, in INR |
Peak value is the highest market value your holding reached on any single day during the calendar year. Your broker's year-end statement shows the closing value on December 31. It does not show the peak value during the year. You need daily stock price data for the entire calendar year, applied to the quantity held on each date, converted at the daily SBI TT rate — to identify which day had the highest INR value.
GainSutra pulls this from a stock price database automatically. Most CAs either skip this field, enter the closing value (incorrect), or calculate it manually from a spreadsheet (error-prone and time-consuming).
GainSutra generates Table A2 and A3 with peak values, closing values and all INR conversions — for the correct calendar year boundary — from your broker PDF.
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