Why does your income tax return ask about January to December when everything else runs from April to March?
That one question confuses more US stock investors than any tax rate. We hear it every filing season at Belong. Investors open Schedule FA in their ITR, see the calendar year dates, and freeze.
Schedule FA is the part of your income tax return where residents disclose foreign assets. If you hold US stocks or ETFs from India, your holdings belong here. So does the brokerage account that holds them.
The schedule is not a tax calculation. It is a disclosure. But getting it wrong can cost far more than the tax on your dividends ever would.
This guide explains how to report US stocks and ETFs in Schedule FA. We go one table and one column at a time.
It is written by our team, led by me, Ankur Choudhary, a SEBI-registered investment advisor and CEO of Belong. We have kept it practical, because this is a form you fill, not a theory you study.
Quick Answer
Are you resident and ordinarily resident in India? Then you must report every foreign asset held at any time in the calendar year. For US investors, that usually means two tables.
Table A2 for your foreign brokerage or custodial account.
Table A3 for each US stock or ETF you held.
Values are converted to rupees using the SBI telegraphic transfer buying rate on the relevant date. The reporting period is the calendar year ending 31 December before the assessment year.
These rules come from the department's own step-by-step guide to Schedules FSI, TR and FA. The rest of this guide shows you how to apply them.
Tip: Schedule FA is about what you owned, not what you earned. Even a stock that paid nothing and lost value must be reported.
Who Must Fill Schedule FA
Start here, because many readers do not need this schedule at all.
The department's guide says residents must furnish details of foreign assets in Schedule FA. Non-residents and those who are not ordinarily resident do not need to complete it.
Your status depends on your days in India, not your passport. Our explainer on residential status under income tax walks through the day-count rules.
If you are a resident Indian investing abroad
If you live in India and invest in US stocks through LRS, you are almost certainly ROR. Schedule FA applies to you every single year you hold a foreign asset.
It applies even in a year when you made no new investment. It applies even if the holding is tiny.
If you are an NRI
If you are working in Dubai or living in the US, Schedule FA is not part of your Indian return. Your foreign holdings are reported, if at all, under the rules of the country where you live.
The change comes when you move back. We cover that transition later, because it is where most returning Indians slip.
The Calendar Year Rule, Explained Slowly
This is the heart of the confusion. Let us take it slowly.
Your ITR covers a financial year, from April to March. But Schedule FA does not. The department's guide says you report assets held at any time during the calendar year ending 31 December.
The calendar year used is the one that ends inside the financial year you are filing for. For assessment year 2026-27, the financial year is April 2025 to March 2026. The calendar year that ends inside it is January to December 2025.
So in your AY 2026-27 return, Schedule FA covers 1 January 2025 to 31 December 2025.
Why this creates odd situations
Say you bought your first US ETF in February 2026. That falls in FY 2025-26, so it belongs to the AY 2026-27 return year. Yet it falls outside calendar year 2025.
So it does not appear in Schedule FA for AY 2026-27. It appears in the next year's Schedule FA instead.
Now flip it. Say you sold all your US shares in November 2025.
Your financial year capital gains sit in AY 2026-27. Your Schedule FA for that same return also shows the holding, because you held it during calendar 2025.
Neither of these is a mistake. It is simply how the schedule is designed. The mistake is assuming the two periods match.
Tip: Keep two folders for each return: one for April to March income, one for January to December holdings. Never mix them.
The reflective part of this rule
It is easy to see this as bureaucracy. We see it a little differently.
Calendar-year reporting matches how most foreign institutions report to tax authorities. It lets the department compare your disclosure with data received from abroad. Seen that way, the rule is less about you and more about making that comparison possible.
Which Table Does Each US Holding Go Into?
Schedule FA has several tables. Most US stock investors use only a few of them. Here is the map.
The department's guide confirms A2 covers accounts with foreign custodians and A3 covers foreign equity and debt. It does not name brokers or ETFs specifically. In practice, most tax professionals place the brokerage account in A2 and each security in A3.
Why the account and the shares are separate
A common question: if the shares sit inside the broker account, why report both?
Because they are different things. The account is a container held with a foreign custodian.
The shares are your interest in foreign companies or funds. Schedule FA asks about both.
Think of it like a locker and the jewellery inside it. The locker has its own details. Each piece has its own value.
What about RSUs and ESPP shares?
Many residents working for US companies hold shares through stock plans. Vested shares are foreign equity, so they belong in Table A3.
Unvested RSUs raise harder questions about ownership. Treatment can vary with the plan terms. Take professional advice before deciding how to treat them.
Filling Table A2: Your Broker Account
Table A2 is about the account, not the securities. You report its details and the money that flowed through it.
Columns you will see
The department's guide lists what A2 needs. You report the peak balance and the closing balance of the account. You also report gross amounts paid or credited to the account, split by type.
Those types are interest, dividend, proceeds from sale or redemption, and other income. You will also enter the institution's name and address and the account number. The account status and opening date are needed too.
What "balance" means for a broker account
This is where investors hesitate. Does balance mean cash only, or cash plus shares?
Practice varies. Many professionals treat the A2 balance as the cash in the account.
The securities are reported separately in A3. Reporting the full account value in both tables would double count your holdings.
Whatever approach you take, apply it consistently every year. Keep a short note in your records explaining the method.
Gross amounts credited
Report gross figures, not net. Dividends should be shown before US tax withholding. Sale proceeds should be the gross amount received on sale.
These figures should reconcile with your broker's statements for the calendar year. That reconciliation is your best defence if questions ever come.
Filling Table A3: Each Stock and ETF
Table A3 does most of the work for a US investor. Each stock or ETF gets its own row.
If you hold five stocks and two ETFs, you need seven rows. A stock sold during the year still needs a row. You held it at some point during that calendar year.
The columns, one by one
Here is what the department's guide asks for in A3, in plain words.
Country name and code.
For US holdings, this is the United States.Name of the entity.
The company or ETF issuer, such as the full legal name.Address and ZIP code.
The registered address of the company or fund.Nature of entity.
For example, company or fund.Date of acquiring the interest.
When you first bought the holding.Initial value of the investment.
What it cost you, in rupees.Peak value during the period.
The highest value of your holding during the calendar year.Closing value.
Your holding's value on 31 December.Total gross amount paid or credited.
Usually dividends received on that holding.Total gross proceeds from sale or redemption.
What you received on selling during the year.
Initial value: your cost
Initial value is your cost of acquisition. Convert it at the SBI telegraphic transfer buying rate on the date of investment, as the guide specifies.
If you bought the same stock on several dates, you have a choice to make. Some investors use the first purchase date for the row.
Others compute a combined cost from all lots. Pick one approach, document it, and stay consistent.
Peak value: the trickiest column
Peak value is the highest value of your holding during the calendar year. It is not the highest share price alone. It is price multiplied by the number of units you held on that day.
That distinction matters if you bought more units during the year. A lower price on a day when you held more units can produce a higher peak value.
The guide says to convert peak value at the TT buying rate on the date of the peak. So you need the date, the units held, the price, and the exchange rate on that date.
Closing value: 31 December
Closing value is your holding's value at the end of the calendar year. Use the closing price on the last trading day, the units held, and the TT buying rate for 31 December.
If you sold the entire holding before December, the closing value is nil. The row still stays, because you held it during the year.
Gross amount and gross proceeds
The gross amount column usually captures dividends on that holding during the calendar year. Use the gross figure before US withholding.
Gross proceeds capture sale amounts. Again, use the gross figure before any fees or deductions.
Tip: A single spreadsheet with one tab per holding makes A3 almost mechanical. Track units held, daily closing prices, and dividends for the calendar year.
Exchange Rates: Getting the Conversion Right
Every value in Schedule FA must be in rupees. The question is which rate to use.
The department's guide specifies the SBI telegraphic transfer buying rate. The date depends on the column. It is the peak date, the investment date, or the year's closing date.
The Black Money Act uses a similar approach. Its section 42 converts foreign currency values at SBI's TT buying rate. The rate is taken on the valuation date.
What most guides skip
Here is a subtle point. The peak in dollars may not be the peak in rupees.
The rupee value depends on both the share value and the exchange rate on that day. A day with a slightly lower dollar value but a weaker rupee can produce a higher rupee figure.
The schedule asks for peak value during the period. A careful approach checks the rupee value across the year, not just the dollar value.
This takes more work. It also produces the most defensible number.
Do not use a single average rate
Some investors apply one average rate to every column. It is quick, and it is wrong for this schedule.
Each column has its own date, and each date has its own rate. Using a single rate makes your numbers harder to reconcile later.
A Worked Example in Words
Let us walk through one investor's Schedule FA. We will keep it in words so the logic stays clear.
Karthik is a salaried professional in Chennai. He is resident and ordinarily resident. In 2025, he held a US brokerage account with three holdings: two US companies and one broad US ETF.
He bought the ETF in 2023. He bought the first company in 2024. He bought the second company in March 2025 and sold it in October 2025.
His Table A2 row
Karthik has one broker account, so he fills one row in Table A2. He enters the broker's name, address, account number, and opening date.
He reports the peak and closing cash balance for calendar 2025, converted at the right rates. He also enters gross dividends credited and gross sale proceeds received during the year.
His Table A3 rows
He needs three rows in Table A3, one for each holding.
For the ETF, the acquisition date is in 2023. Initial value is his cost, converted at the rate on that date. Peak and closing values come from 2025 data.
For the first company, the logic is the same, with a 2024 acquisition date.
For the second company, he bought and sold within 2025. He enters the purchase date and cost. His peak value is the highest rupee value while he held it.
His closing value is nil. His gross proceeds show the sale amount.
What happens to the income
Karthik's dividends also appear in Schedule FSI as foreign source income, by country. Any US tax withheld appears in Schedule TR. His capital gain on the second company appears in his capital gains schedule.
Notice the different time frames. Schedule FA uses calendar 2025.
His income schedules use April 2025 to March 2026. He maintains two clean data sets and fills each schedule from the right one.
Total time: about three hours the first year. Next year, with his spreadsheet ready, closer to one.
How Schedule FA Connects With the Rest of Your ITR
Schedule FA rarely stands alone. It sits beside other schedules that should tell the same story.
The department's guide explains these links. Schedule FSI reports all foreign source income by country, including tax paid abroad. Schedule TR summarises the foreign tax relief claimed, country by country.
To claim foreign tax credit, you also need to file Form 67 under the current rules. We have covered Form 67 separately in our US stocks and ETFs series.
The guide also says assets reported in Schedule FA must be reported in Schedule AL, where that schedule applies. Schedule AL covers assets and liabilities for higher-income filers.
Which ITR form to use
The department's guide says not to use ITR-1 or ITR-4 if you have foreign assets or income. Those forms lack Schedule FA.
Most salaried investors with US stocks use ITR-2. Those with business income use ITR-3.
Choosing the wrong form is one of the most common reasons a return needs revision. Get this right before you start entering numbers.
Your AIS and what the department already knows
Your annual information statement shows data the department has received about you. Our guide to the annual information statement explains how to read it.
For foreign assets, information can also flow through international exchange frameworks. The department's NUDGE page on Schedule FA links to a note on CRS and FATCA. Its theme is tax transparency on foreign assets and income.
The direction is clear. Foreign holdings are increasingly visible.
ETF-Specific Questions Investors Ask Us
ETFs raise a few questions that individual stocks do not. Here are the ones we hear most.
Is a US ETF a company or a fund for Schedule FA?
ETFs are investment funds, so many professionals record the nature of entity as a fund. The department's guide does not name ETFs specifically. Use a consistent description and keep the issuer's legal name accurate.
Our explainer on ETFs vs mutual funds covers how these structures differ.
What about ETFs domiciled outside the US?
Some Indian investors hold ETFs domiciled in Ireland or elsewhere, bought through a US or international broker. For Schedule FA, the country is the fund's country, not the broker's.
So an Ireland-domiciled ETF goes in A3 with Ireland as the country. The broker account still sits in A2 under the broker's country. Mixing these up is a common error.
Fractional shares and dividend reinvestment
Fractional shares are still foreign equity. Report them in the same row as the full units of that holding.
Reinvested dividends add units. Your peak and closing values must reflect the higher unit count. The dividend itself still counts as a gross amount credited.
Stock splits and corporate actions
A split changes the number of units and the price, but not the value. Make sure your unit counts and prices are on the same basis before computing peak value.
Mergers and spin-offs can create new holdings. A new holding usually needs its own row from the date you received it.
Tip: After any corporate action, re-check your unit history in your broker's records before you compute values.
Common Schedule FA Mistakes and Fixes
Here is a mistake table built from real conversations with investors.
Our broader guide on reporting mistakes with USD investments covers related errors across other dollar assets.
The behavioural root
Most of these mistakes come from one habit. Investors treat Schedule FA as a copy of their broker's year-end summary.
The broker summary helps. It is not a Schedule FA.
You still have to convert, reorganise, and compute peaks. Accepting that early saves a lot of rework.
What Happens If You Skip or Misreport Schedule FA
Please read this section slowly. The consequences are serious, and they sit outside the regular Income-tax Act.
The Black Money Act
Foreign asset disclosure is backed by the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015. Two sections matter most for investors.
Section 43 covers residents who file a return but fail to report foreign assets or income, or report them inaccurately. The Assessing Officer may direct a flat penalty set by the section. It applies per return, not per asset.
Section 42 covers residents with foreign assets who must file a return. It applies if they do not file before the assessment year ends. The same flat penalty applies there.
The relief for smaller holdings
Both sections now carry a proviso. The penalty does not apply below a value threshold set in the Act. The threshold covers foreign assets other than immovable property.
As per the department's text of section 43, this proviso was substituted by the Finance (No. 2) Act, 2024, from 1 October 2024. Earlier, the exception covered only small bank account balances.
Please note what this relief does. It removes the penalty under these sections for smaller movable holdings.
It does not remove the duty to disclose. Schedule FA must still be filled correctly.
Tip: Never treat the penalty threshold as a reporting threshold. The duty to report exists from the first share you buy.
The filing duty itself
Section 42 ties the duty to file to section 139(1) of the Income-tax Act and its provisos. In practice, holding foreign assets can bring a resident into the filing net even in a low-income year.
If you hold US stocks and are unsure whether you must file, assume you should. Then confirm with a tax professional.
Why "nobody will notice" is a weak bet
The department's NUDGE page exists to guide taxpayers on Schedule FA, FSI and TR. It recommends filing a revised return by the due date for legal security.
When a tax department builds a dedicated outreach page, it is telling you where it is looking. Take the signal seriously.
Our guide to avoiding tax penalties covers broader penalty risks and how to stay clear of them.
How to Fix a Missed or Wrong Schedule FA
If you are reading this in late 2026, your most recent return is for AY 2026-27. That return should show your holdings for calendar 2025.
Left Schedule FA blank or got it wrong? The NUDGE page points to a revised return filed by the due date. A revised return replaces your original return with corrected details.
Act sooner rather than later. Revision windows close, and corrections become harder once they do.
A short checklist for fixing it
Confirm you were resident and ordinarily resident for that year.
Pull broker statements for the full calendar year.
Rebuild your A2 and A3 rows with correct values and rates.
Check that FSI, TR, and your capital gains schedule agree.
File the revised return and e-verify it.
Save your working sheets with the acknowledgement.
If older years were also missed, speak to a tax professional before acting. The right route depends on which years are still open.
The Return to India Layer
Now, a word for NRIs and those planning to come home. This is where Schedule FA catches people unprepared.
While you are abroad
As an NRI, you do not fill Schedule FA in your Indian return. Your US brokerage, your US ETFs, your foreign retirement accounts stay outside this schedule.
During RNOR years
After returning, you may be RNOR for a period. The department's guide says not ordinarily resident taxpayers do not need to complete Schedule FA.
Our guide to how tax status changes between NRI, resident and RNOR explains how long this phase may last.
The first ROR year
The year you become ROR, everything changes at once. Every foreign account and holding enters Schedule FA.
The calendar year rule kicks in. Peak values need computing for assets you may have held for a decade.
Consider a returning engineer from Seattle. He moved back to Bengaluru with a brokerage account, a US retirement account, and an old US bank account. In his first ROR year, all three need disclosure in Schedule FA.
He had never heard of Schedule FA. His first resident return went in without it. A revised return, two professionals, and many anxious weeks later, it was fixed.
What returning Indians should do
Estimate the year your RNOR status ends.
List every foreign account, holding, and retirement plan you will carry.
Decide which to keep, consolidate, or close before that year.
Start calendar-year records for each one from the first ROR year.
Our article on whether to exit US ETFs before moving to India helps with that decision. Our guide to 401(k) retirement planning is useful if you carry a US retirement account home.
Is Direct US Investing Worth the Reporting Work?
Let us zoom out. If your portfolio is entirely in India today, all of this may feel like a reason to stay home.
We understand that reaction. We also think it is the wrong conclusion.
Global investing from India spreads your risk beyond one economy and one currency. Indian investors are often overexposed to India through salary, property, and domestic funds.
A US allocation is a sensible counterweight. Our guide to building a portfolio outside India explains the case.
The reporting work is real but manageable. Once your spreadsheet exists, Schedule FA becomes an annual update, not a project.
Your routes, compared
Not every route creates the same reporting load. Here is a planning view.
Our explainer on US stocks vs global mutual funds compares the first two routes. For GIFT City, see whether GIFT City investments need to be reported in your ITR.
Our GIFT City mutual funds tool lets you compare global funds. One example is the DSP Global Equity Fund. Treat it as a comparison shortcut, not a recommendation.
The LRS step before any of this
If you invest directly, your money leaves India under the Liberalised Remittance Scheme. The RBI's LRS Master Direction permits overseas portfolio investment by resident individuals. Our guide to sending money abroad for investments covers the process.
Keep your LRS remittance records with your Schedule FA files. Our piece on documentation issues with USD investments explains which papers matter most.
Decision Clarity
Use this quick filter to decide your next step.
ROR and held any US stock or ETF in calendar 2025? Report it in Schedule FA for AY 2026-27.
If you sold a holding during the calendar year, still include it, with a nil closing value.
If your return omitted Schedule FA, prepare a revised return before the window closes.
If you are NRI or RNOR, Schedule FA generally does not apply to you this year.
If your return to India is close, plan your foreign holdings before your first ROR year.
If you want global exposure with less annual reporting, compare GIFT City and domestic routes first.
What resident Indians should do
Build one calendar-year spreadsheet for your foreign holdings. Fill A2 and A3 from it every year. Keep your FSI, TR and Form 67 numbers aligned on the financial year.
What NRIs should do
While abroad, focus on reporting in your country of residence. Mark the year you expect to become ROR, and prepare your records before it arrives.
Your Annual Schedule FA Calendar
Our document checklist for tax filing can help you build the folder.
Your foreign holdings are part of your total net worth. Tracking each foreign asset carefully also helps you judge its liquidity when you need cash.
Beyond Schedule FA: The Rest of Your Money Map
Filing season is also a useful moment to review the rest of your finances. A few pointers from our wider library follow.
For NRIs building savings in India
Comparing deposits as an NRI? Our guide to GIFT City FDs vs FCNR, NRO and NRE FDs explains the trade-offs.
Our NRI FD rates tool shows current offers. Our USD fixed deposits page covers dollar deposits in GIFT City.
Planning a home in India? Start with our guide to NRI home loans. A healthy CIBIL score will matter for that loan.
For returning residents resetting daily finances
Coming home often means new cards and new banking habits. Our guide to the best credit cards in India is a practical starting point.
For global investors from India
Our guide on how to invest in the USA from India covers every major route. For Indian equities, our best stocks list is a research starting point, not advice to buy.
Through GIFT City, you can also look at the Edelweiss Greater China Equity Fund for regional exposure. India-focused options include the Tata India Dynamic Equity Fund and the Sundaram India Mid Cap Fund.
Larger portfolios can compare options on our GIFT City alternative investment funds tool. Our mutual funds page lists what is available on our platform.
For market watchers
Our GIFT Nifty tracker shows how Indian markets may open. The GIFT Nifty weekly outlook adds weekly context. For deeper study, see GIFT Nifty historical data and our explainer on reading the GIFT Nifty chart.
Active traders can read our guide to GIFT Nifty futures and visit our futures and options page. For new listings, see our GIFT City IPO explainer and our IPO page.
Need Help With Your Schedule FA?
Schedule FA is detailed work. If you would rather have experts handle it, our tax filing service supports residents and returning Indians with foreign assets.
We work as a regulated platform. You can review our registrations on our licenses page. Please check credentials before trusting anyone with your filings, including us.
Frequently Asked Questions
Do I need to report US stocks in Schedule FA if I sold them before December?
Yes. Schedule FA covers assets held at any time during the calendar year. A holding sold in October still needs a row, with a nil closing value and the sale proceeds shown.
What period does Schedule FA cover for AY 2026-27?
It covers 1 January 2025 to 31 December 2025. The department's guide uses the calendar year ending 31 December, not the April to March financial year.
Which exchange rate should I use in Schedule FA?
Use the SBI telegraphic transfer buying rate. Apply it on the date of investment, the date of peak value, or 31 December, depending on the column.
Do NRIs need to fill Schedule FA?
No. The department's guide says non-residents and not ordinarily residents do not need to complete Schedule FA. It applies once you become resident and ordinarily resident.
Is there a minimum value below which I need not report?
There is no reporting threshold for disclosure. The Black Money Act has penalty relief for smaller movable holdings, as per section 43. That relief covers the penalty only, not the duty to report.
Sources
Income Tax e-filing portal, Step-by-step guide to fill FSI, TR and FA schedules in ITR
Income Tax e-filing portal, NUDGE on Schedule FA
Income Tax Department, Section 43 of the Black Money Act, 2015
Income Tax Department, Section 42 of the Black Money Act, 2015
Reserve Bank of India, Master Direction on the Liberalised Remittance Scheme
Disclaimer
This article is for general education only. It is not tax, legal, or investment advice. ITR forms, schedules, and penalty provisions change, and India's transition to the Income-tax Act, 2025 may alter future forms. Your obligations depend on your residential status and personal facts. Please verify current rules on the official income tax portal and consult a qualified tax professional before filing. Belong and its team are not responsible for decisions taken solely on the basis of this article.