If you hold RSUs at a large tech employer, you get an email every vest date telling you shares landed in your account. Most people stop there.
The account itself, whether it is run through Schwab Equity Award Center, Fidelity NetBenefits, Morgan Stanley StockPlan Connect, or another stock plan platform, holds a lot more than a vesting notification. It holds the exact records your CA needs to file your Indian return correctly.
The exact section names below (Awards, Positions, Transaction History, Tax Lots, Gain/Loss Report) are common across stock plan platforms but not identical. Your specific platform may label or group these differently. Treat the descriptions here as what to look for, not an exact menu you'll find in every login.
You may see it said that specific employers use specific brokers, for example, that one company's plan always runs through one particular platform. Employer-broker pairings do shift over time and by region, so don't treat any one pairing as fixed. Check your own equity plan login to confirm which platform administers your grants.
Table of contents
- Awards: what was granted to you
- Positions: what you currently hold
- Transaction history: the activity log
- Tax lots: the record that drives your tax calculation
- Gain/Loss report: realized and unrealized, in the broker's own terms
- What your CA actually needs from all of this
- The calendar-year trap: your statement's dates don't match your ITR's dates
Awards: what was granted to you
This section lists each RSU grant you've received, typically showing the grant date, total number of units granted, and the vesting schedule for that grant. This is the closest thing to your original offer letter translated into a live record. If you've had refresher grants on top of your initial grant, each one usually appears here as a separate award with its own vesting timeline.
This section by itself does not tell you anything about tax. It only tells you what is scheduled to vest and when. Nothing in the Awards section is a taxable event until units actually vest and shares land in your account.
Positions: what you currently hold
Positions shows your current holdings, the number of vested shares sitting in the account right now, unsold and uncommitted. This is a snapshot as of today, not a history.
For Indian tax purposes, what matters is not just how many shares you hold today, but when each batch of those shares arrived, because each vesting event is taxed and tracked separately.
Transaction history: the activity log
Transaction History is the ledger of everything that has happened in the account: vesting events (shares credited), sell-to-cover transactions (shares sold automatically to fund withholding), voluntary sales, and dividend payments if the underlying stock pays one.
This is the section to export when you need a full record of activity for a period. If you sold shares mid-year, the transaction confirming that sale, with date, quantity, and price, lives here.
Example: suppose you are trying to reconstruct what happened to a grant that vested in three tranches over the year. Transaction History would show three separate 'shares deposited' entries (one per vest date) and, if you used sell-to-cover, a corresponding sale entry next to each vesting entry for the shares sold to cover withholding tax.
Tax lots: the record that drives your tax calculation
This is the section that matters most for your Indian tax return, and the one people skip most often.
Every time RSUs vest, that batch of shares becomes its own tax lot. Each vesting creates a separate lot, and every lot must be tracked independently for tax purposes, because each lot has its own cost of acquisition.
When shares eventually get sold, lots from different vesting dates cannot be combined into a single calculation, and doing so anyway can produce the wrong capital gains figure and the wrong tax treatment.
For each lot, the Tax Lots section typically shows:
- Acquisition date: this is your vest date, not the grant date. For RSU shares, the holding period used to determine short-term versus long-term treatment is counted from the vesting date to the sale date, not from grant date.
- Quantity: number of shares in that lot.
- Cost basis: on US brokerage statements, this is usually shown in USD, based on the fair market value (FMV) at vesting. For your Indian return, the cost of acquisition is that same vesting-date FMV, converted to INR, and it becomes the figure used to compute your capital gain when the shares are sold. The share's original grant price has no bearing on the tax you owe.
Reading the 24-month clock on a single lot
Take one lot and look at its vest date. Count forward. Shares held up to 24 months from that vest date are treated as short-term capital gains (STCG) and taxed at your income slab rate.
Shares held for more than 24 months from vest date are treated as long-term capital gains (LTCG) and taxed at 12.5%, without indexation.
Example: suppose you are looking at a lot that vested on 1 April 2025. If you sell those shares any time before 1 April 2027, the gain on that specific lot is short-term. If you sell on or after 1 April 2027, it's long-term.
A different lot from the same grant, vesting six months later, runs its own 24-month clock starting from its own vest date.
| Lot | Vest date | 24-month LTCG threshold | Status if sold today (assume today = 15 Sept 2027) |
|---|---|---|---|
| Lot 1 | 1 Apr 2025 | 1 Apr 2027 | LTCG (held past threshold) |
| Lot 2 | 1 Oct 2025 | 1 Oct 2027 | STCG (not yet past threshold) |
The result: the same sale order can straddle both short-term and long-term treatment if it touches shares from more than one lot, which is exactly why each lot's own vest date, not a blended average, is needed.
Gain/Loss report: realized and unrealized, in the broker's own terms
This report shows gains or losses on shares you've sold (realized) and, often, an estimate of gain or loss on shares you still hold (unrealized), based on the platform's own cost basis figures.
Be careful with this report. It's built for US reporting conventions, generally in USD, using the broker's own cost basis and its own short-term/long-term cutoff (the US line is one year, not India's 24 months). Do not treat this report's 'short-term' or 'long-term' label as your Indian tax answer. It's a useful cross-check for quantities and dates, not a substitute for the lot-by-lot, INR-converted calculation described above.
What your CA actually needs from all of this
Form 16 alone is not enough. It's useful for salary reporting, but you'll also need brokerage statements, vesting records, and sale confirmations to calculate capital gains and complete your ITR. Broken down by purpose:
- For salary reporting: Form 16, vesting statements, and payslips, to report the salary income that arises from RSU vesting. Form 16 shows the salary income and tax deducted at the time your RSUs vested, but it does not contain everything needed to calculate capital gains when you sell shares. The TDS your employer withholds on vesting (usually under Section 192 of the Income-tax Act) is reflected in Form 16 and can be claimed against your final liability when filing.
- For capital gains: the Tax Lots section (or an exported transaction history covering the same lot-level detail), plus sale confirmations, so gains are computed lot by lot rather than in aggregate.
- For Foreign Tax Credit (Form 67): Form 67 itself, along with foreign tax statements and proof of taxes withheld abroad, to claim credit for eligible foreign taxes paid. Form 67 must be filed on the Income Tax Portal before you file your actual ITR.
- For Schedule FA (foreign asset disclosure): foreign brokerage statements and a year-end holdings statement, to report foreign assets held during the relevant reporting period. Brokerage statements are what let your CA determine the initial, peak, and closing values Schedule FA asks for.
- Cross-check against Form 26AS and AIS: Form 26AS shows taxes deducted or collected on your behalf, and the Annual Information Statement (AIS) should be checked to verify your reported income matches what the Income Tax Department already has on file.
The calendar-year trap: your statement's dates don't match your ITR's dates
This is where most of the confusion around equity plan statements comes from, and it isn't really about the statement itself. It's about two different calendars applying to the same shares.
Your US brokerage statement, and most of the exports it offers, run on the calendar year (January to December), because that's the US tax year. Your Indian ITR, for most purposes, runs on the financial year (April to March).
But Schedule FA, the section of your ITR where you declare foreign assets, asks you to disclose foreign assets held between January 1 and December 31 of the calendar year that falls within the financial year. So within one ITR, you are reporting salary and capital gains for an April-to-March window, and foreign asset holdings for a January-to-December window, at the same time.
Example: suppose you are filing your ITR for AY 2026-27 (FY 2025-26). Your capital gains and salary income get reported for the financial year 1 April 2025 to 31 March 2026 as usual, but the Schedule FA disclosure for that same return covers a different window: 1 January 2025 to 31 December 2025.
A lot that vested in February 2025 falls outside FY 2025-26 for salary and gains purposes, but it still needs to be disclosed in that year's Schedule FA, because it was held during the January-December calendar year.
It also does not matter whether you sold the shares later in the year, whether the value went up or down, or whether you received dividends: if you held the shares at any point during the January-December window, they belong in Schedule FA for that year.
Even if you sold everything before December 31 and the closing value is zero, the disclosure itself is still required. Unvested RSUs are the one thing you don't disclose. They aren't an asset you own yet, only a promise of future shares conditional on continued vesting. The disclosure obligation starts on the date shares actually vest and land in your account.
For each vesting tranche in Schedule FA's Table A3 (the table where foreign equity, including RSU shares, is reported), your CA will typically need, per lot: the vest date as the date of acquisition, the initial value (cost of acquisition, matching the perquisite value already in your Form 16), the peak value your holding reached at any point in the January-December window, and the closing value on 31 December.
All of this comes straight out of your Positions and Transaction History sections, provided you pull the right calendar-year window and not your financial-year default view.
Getting this wrong is not a small paperwork issue. The penalty for not filing Schedule FA runs up to ₹10 lakh per year under the Black Money (Undisclosed Foreign Income and Assets) Act, and it applies per year of non-disclosure regardless of whether you owed any additional tax. As amended by the Finance (No. 2) Act 2024, this penalty doesn't apply if your aggregate undisclosed foreign assets (other than immovable property) stayed under ₹20 lakh at any point during the year, though that's an exemption from the penalty, not from the underlying obligation to disclose.
