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Schedule FA · Form 67 · AY 2026-27

The RSUs you did not sell still go in the return

Vesting is taxed as salary and your employer usually handled it. What the Form 16 cannot do is disclose the shares you are still holding — and that obligation runs every year, in a schedule that ITR-1 does not have.

Three obligations, and they come apart

The mistake is treating this as one event. Vesting, holding and selling are taxed and reported separately, and the middle one has no tax attached at all — which is exactly why it gets missed.

When they vest

Taxed as salary, in the year of vesting, on the value at vesting. Your employer normally deducts tax and it reaches the return through Form 16, so this part usually looks after itself.

While you hold them

No tax. But if you are resident and ordinarily resident, the holding is disclosed in Schedule FA for every year you hold it. Nothing was sold, nothing was earned, and the disclosure is still required.

When you sell

A capital gain, computed in the ordinary way, plus any dividends received along the way. If the other country taxed either, the credit is claimed under Section 90, 90A or 91.

Schedule FA is wider than shares

Ten sub-tables, and an employee with a foreign brokerage account is usually in two of them without realising it.

TableWhat belongs in it
Foreign bank accountsAny account held outside India
Custodial accountsThe brokerage account your RSUs vest into
Equity and debt interestThe shares themselves
Cash-value insurancePolicies with a surrender value
Financial interest in an entityBeneficial ownership
Immovable propertyReal estate abroad
Other capital assetsIncluding crypto on a foreign platform
Signing authorityAn account you can operate but do not own
Foreign trustsAs settlor, trustee or beneficiary
Other foreign incomeAnything from a source outside India

Non-disclosure of a foreign asset is dealt with under the Black Money Act, 2015, separately from anything in the Income-tax Act. The obligation is not proportionate to the size of the holding, which is the part that surprises people about a single vested lot.

Form 67 comes before the return

A foreign tax credit under Section 90, 90A or 91 is supported by Form 67, furnished online at incometax.gov.in. Under Rule 128 it has to be filed on or before the due date u/s 139(1) for the credit to be admissible — 31 August 2026 for a non-audit case in AY 2026-27.

Filed after the return, or not at all, the credit can be denied even though the foreign tax was genuinely paid. BharatTax produces the Form 67 worksheet from the same figures the return uses; you furnish it on the portal, and you do that first.

The form you can no longer file

A foreign asset disqualifies ITR-1 and ITR-4 outright. It does not matter that the rest of the return is a single salary and a savings account, and it does not matter how small the holding is.

So a salaried employee whose company granted them one lot of shares is an ITR-2 filer from that year onward. The form chooser applies the same disqualification rules the product applies to your own answers.

Questions

I have RSUs from my employer. What do I report?
Two different things, in two different places. The vesting itself is taxed as salary and your employer has usually deducted tax on it already, so it reaches the return through the Form 16. The shares you continue to hold are a foreign asset, and they go in Schedule FA — every year you hold them, whether or not you sold anything.
Do I have to file Schedule FA if I did not sell anything?
Yes. Schedule FA is a disclosure obligation, not a tax one. If you are resident and ordinarily resident and you held a foreign asset at any point in the relevant period, it is disclosed — a vested holding sitting in a foreign brokerage account with no activity at all still belongs in the schedule.
Where does an employee stock account go in Schedule FA?
A brokerage or custodial account goes in the custodial-account table, and the shares themselves in the equity and debt table. BharatTax carries all ten of the schedule’s sub-tables, including foreign bank accounts, immovable property, cash-value insurance, trusts and signing authority over an account you do not own.
I paid tax in the other country. Do I pay again here?
Not twice on the same income, if the credit is claimed properly. Relief comes under Section 90 or 90A where there is a treaty and Section 91 where there is not, and it is claimed through Schedule TR and Schedule FSI.
What is Form 67 and when is it due?
Form 67 is the statement that supports a foreign tax credit claim under Rule 128, and the timing is the part that catches people: it must be furnished online at incometax.gov.in on or before the due date u/s 139(1) for the credit to be admissible. BharatTax produces the Form 67 worksheet from your figures; you file it on the portal, and you do that before the return.
Which ITR form do I need?
ITR-2, or ITR-3 if you also have business or professional income. A foreign asset disqualifies ITR-1 and ITR-4 outright, regardless of how small it is or how ordinary the rest of your return looks — which is why a salaried employee with one vested RSU lot is no longer a Sahaj filer.

Get the disclosure right, not just the tax

Schedule FA from your brokerage statement, the capital gain on what you sold, and the Form 67 worksheet for the tax the other country already took. Nothing is payable until you download the JSON to file with.

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