RSU year-end checklist for Indian engineers: what to do before March 31, 2026

March 31 marks the end of the Indian financial year. For RSU holders, it is also the deadline by which several irreversible tax decisions must be made. Actions you take in the last two weeks of March can save significant tax; actions you miss cannot be undone after April 1.

This checklist covers everything an Indian engineer with US RSUs should complete before March 31 for FY 2025-26.

Priority 1: File Form 44 (dividend withholding credit)

Deadline: Before ITR filing due date — which starts with March 31 financial year close.

Form 44 (renamed from Form 67; effective from TY 2026-27 for FY 2025-26 returns) is the foreign tax credit claim for US dividend withholding. If you hold dividend-paying US stocks — AAPL, MSFT, GOOGL, AMAT, HPQ, TI, CSCO, QCOM, AVGO, DELL, or US ETFs that distribute dividends — your broker withheld 25% of gross dividends for US tax.

You can claim this 25% WHT as a foreign tax credit in India, reducing your Indian tax liability on that dividend income. The mechanism is Form 44 + Schedule TR in ITR-2.

Why this is Priority 1: If you miss filing Form 44 before the ITR due date, you permanently lose the credit. It cannot be claimed in a revised return filed after the due date. The Supreme Court (and multiple High Court decisions) have held that the FTC claim requires the prescribed form to be filed in time.

Action before March 31:

• Collect all Form 1042-S documents from your US broker (available in the broker's tax center, typically by mid-February)
• Note: Form 1042-S shows gross dividends and US WHT for calendar year 2025
• File Form 44 on the ITD portal (incometax.gov.in → e-File → Income Tax Forms → Form 44) for each country/company
• Keep the acknowledgement number — you'll reference it in Schedule TR of ITR-2

Priority 2: Pay March 15 advance tax installment

Deadline: March 15

The final advance tax installment for FY 2025-26 is due March 15. By this date, 100% of your estimated total tax for the year should be paid through:

• TDS deducted by your employer (from payroll + RSU sell-to-cover)
• Any advance tax payments you made in June, September, December

Compute your estimated total tax:

Income source	Estimated amount (INR)
Salary (excluding perquisites)	From latest payslip × months
RSU perquisites (gross vest value in INR)	Each vest: shares × FMV × SBI TTBR
Capital gains on US stocks sold (if any)	From broker transaction history
US dividends (gross, INR)	From Form 1042-S × SBI TTBR
Interest income, other	From bank statements

Action before March 15:

• Add up all perquisite income from April 1, 2025 – March 31, 2026
• Add estimated perquisite from any March vest events
• Add capital gains from any RSU/stock sales April 2025–March 2026
• Compute total estimated tax liability
• Subtract TDS already deducted (from Form 26AS)
• Pay balance via Challan 280 (Self-Assessment Tax / Advance Tax) on incometax.gov.in
• Save the Challan 280 BSR code and serial number

Priority 3: Execute tax-loss harvesting before March 28

Deadline: March 28 (US stock T+1 settlement must complete by March 31)

If you hold RSU or other US stock lots that are underwater (current price < your cost basis, i.e., vest-date FMV × SBI TTBR), selling before year-end creates a capital loss you can use to offset gains.

Loss set-off rules:

• STCG loss (lot < 24 months old): offsets STCG gains first, then LTCG gains
• LTCG loss (lot ≥ 24 months old): offsets LTCG gains only
• Neither can offset salary/perquisite income

Wash sale rule: India has no wash sale rule. You can sell a lot at a loss and repurchase the same stock the next day. The loss is valid for Indian tax purposes.

Action:

• Review all US stock lots held: for each, compare current price to cost basis (vest-date FMV × TTBR)
• Identify underwater lots that are < 24 months old (STCG loss — more flexible offset)
• Identify underwater lots ≥ 24 months old (LTCG loss — offsets only LTCG gains)
• Calculate what gains you have this year (from sales already made April–March)
• Sell underwater lots where the loss offsets gains at a higher tax rate than the selling cost
• Remember: US stock T+1 settlement means the last date to sell is March 28 (settlement on March 31)

Example: If you have ₹5 lakh LTCG gain from a stock you already sold, and you hold an underwater STCG-loss lot with ₹3 lakh unrealised loss — selling before March 28 gives you ₹3 lakh STCG loss that offsets ₹3 lakh of LTCG gain. Tax saving: ₹3 lakh × 12.5% = ₹37,500.

Priority 4: Consider realising LTCG-eligible lots (or waiting)

Deadline: March 31 (holding period decisions)

The 24-month LTCG clock for US stocks means lots vested on or before March 31, 2024 are now LTCG-eligible (≥ 24 months from vest date as of March 31, 2026).

Two decisions:

Sell now for LTCG: If you want to diversify and these lots show a gain, selling now captures the gain at 12.5% LTCG. After April 1, these lots remain LTCG-eligible — but the stock price may move.

Hold through March 31: If you have lots that will cross the 24-month mark on April 1 or May 1 or June 1 — a few weeks or months away — consider waiting for LTCG eligibility before selling. A 17+ percentage point difference in tax rate (30% STCG vs 12.5% LTCG) is worth waiting for.

Action:

• List all RSU lots with vest dates between April 1, 2022 and March 31, 2024 — these are LTCG-eligible as of March 31, 2026
• List all RSU lots with vest dates April 1, 2024 – September 30, 2024 — these cross LTCG eligibility between April 1, 2026 and September 30, 2026. Is it worth waiting?
• For lots crossing LTCG eligibility within 60 days, factor stock concentration risk — are you comfortable holding concentrated for 60 more days?

Priority 5: Verify all vest events for FY 2025-26

Action before filing ITR-2 (due July 31, 2026):

Before the financial year closes, pull a complete vest event record from your broker:

• Log in to your broker (E*TRADE, Fidelity NetBenefits, Merrill Lynch, Morgan Stanley at Work, Schwab)
• Export transaction history: April 1, 2025 to March 31, 2026
• List every RSU/ESPP release event: vest date, shares gross, shares net, FMV at release (in USD)
• Also list calendar year 2025 (January 1 – December 31) separately for Schedule FA

For each vest event, verify:

• Vest date (broker statement date, not email notification date)
• SBI TTBR on vest date (from sbi.co.in → Foreign Exchange Rates → historical TTBR)
• Gross shares released (before sell-to-cover)
• Perquisite value: gross shares × USD FMV × SBI TTBR
• This should match Form 12BA when issued (typically April–May with Form 16)

Common errors to check for:

• Net shares used instead of gross (understates perquisite)
• Wrong vest date (off by 1–2 days, wrong TTBR rate)
• A vest event missed entirely (February or March vests often go to spam)

Priority 6: Collect Schedule FA data (calendar year 2025)

For ITR-2 filing (due July 31, 2026), Schedule FA requires calendar year data: January 1 – December 31, 2025.

Start collecting this now so you're not scrambling in July:

Table A2 data (per account):

• Institution name and address (custodian, not the equity platform brand)
• Account number (your brokerage account number at the custodian)
• Opening balance: shares × price × SBI TTBR on January 1, 2025
• Acquisitions during calendar 2025: all vest events January 1 – December 31, 2025
• Disposals during calendar 2025: all sales January 1 – December 31, 2025
• Peak value: highest share count × highest price during 2025 × SBI TTBR on that date
• Closing value: shares × Dec 31, 2025 price × Dec 31, 2025 SBI TTBR

Table A3 data (per ticker):

• Cost of each lot held on December 31, 2025 (vest-date FMV × SBI TTBR per lot)
• Peak value of holding during 2025
• Closing value on December 31, 2025
• Gross proceeds from any shares sold during 2025 (sale price × SBI TTBR on sale date)

Custodian details quick reference:

Broker platform	Custodian for Schedule FA	Address
E*TRADE	E*TRADE Securities LLC	671 N. Glebe Road, Arlington, VA 22203, USA
Fidelity NetBenefits	National Financial Services LLC	245 Summer Street, Boston, MA 02210, USA
Merrill Lynch	Merrill Lynch, Pierce, Fenner & Smith Inc.	One Bryant Park, New York, NY 10036, USA
Morgan Stanley at Work	Morgan Stanley Smith Barney LLC	2000 Westchester Avenue, Purchase, NY 10577, USA
Schwab	Charles Schwab & Co., Inc.	211 Main Street, San Francisco, CA 94105, USA
Vested Finance	DriveWealth LLC	30 Broad Street, New York, NY 10004, USA

Priority 7: Verify Form 26AS for TDS accuracy

When to check: March–April, after last payroll of FY 2025-26

Form 26AS is the master TDS record. It shows all TDS deducted by your employer, including on RSU perquisites (sell-to-cover proceeds). Mismatches between Form 26AS and your own perquisite calculation create reconciliation issues when filing ITR-2.

Action:

• Log in to incometax.gov.in → e-File → View Form 26AS
• Verify TDS from employer under Part A (employer TAN)
• Confirm the TDS amounts match your payslip TDS deductions
• If a vest event TDS is missing from Form 26AS (employer didn't deposit), contact payroll immediately — missing TDS creates an ITR-2 mismatch

AIS cross-check:

• Also check AIS (Annual Information Statement) → incometax.gov.in → e-File → Income Tax Returns → View AIS
• AIS receives FATCA/CRS data from US brokers on foreign accounts. Your RSU vest values may appear here
• If AIS shows income that doesn't match your records, submit feedback before filing ITR-2

Priority 8: Decide on accumulated positions — concentration risk

This is a strategic decision, not a compliance deadline — but March 31 is a natural review point.

If you have accumulated more than 3–4 years of vested RSUs in your employer's stock (or a prior employer's stock), calculate the concentration:

• Total market value of US stocks from employer RSUs
• Total investable wealth (savings, Indian equity, US stocks, EPF, PPF)
• Concentration = RSU value / total investable wealth

If concentration exceeds 20–25% of total wealth: systematic diversification is worth considering. The first step is identifying LTCG-eligible lots (lowest tax rate), selling those first, and reinvesting into diversified assets (index funds, UCITS ETFs for US exposure without US estate tax).

March 31 is a natural review point because it lets you act before the new financial year creates new vest events that further concentrate the position.

Full checklist summary

By March 15:

• Pay advance tax installment (final; 100% cumulative)
• Include estimate for any March vest events in calculation

By March 28 (US market close):

• Execute any tax-loss harvesting sales (T+1 settlement = March 31 deadline)
• Complete any planned LTCG realisations

By March 31:

• Form 44 filed (if not done earlier) for FY 2025-26 dividend WHT
• LTCG eligibility review: list lots crossing 24 months in coming 60–90 days
• Concentration review: assess RSU weight in total portfolio

Before ITR filing (July 31, 2026):

• Complete broker transaction export (April 1, 2025 – March 31, 2026) for Indian FY
• Complete calendar year 2025 export (January 1 – December 31) for Schedule FA
• Verify each vest event: date, gross shares, FMV, SBI TTBR
• Compute perquisite values in INR per event
• Collect Form 12BA when issued; cross-check against your own computation
• Verify Form 26AS TDS matches payslip TDS
• Prepare Schedule FA data: custodian details, opening/closing balances, peak value
• Prepare Schedule CG data: cost basis and sale proceeds (INR) for each lot sold

Related reading

• Revised ITR-2: how to fix Schedule FA mistakes — if you find errors after filing
• Form 67 step-by-step — foreign tax credit filing
• Schedule FA field-by-field guide — complete foreign asset disclosure
• Advance tax quarterly calendar — quarterly planning for RSU vest income
• STCG vs LTCG loss offset matrix — which losses offset which gains
• Should you sell RSUs at vest or hold? — concentration risk framework

This checklist reflects Indian tax law as of FY 2025-26 (AY 2026-27). Deadlines, forms, and procedures can change via Finance Act amendments or CBDT circulars. Verify current requirements with a CA before taking action. Not tax advice.