The IRS issued Revenue Procedure 2026-28 on 24 July 2026, relieving foreign FIFA member associations competing in the 2026 World Cup from annual Form 990, 990-EZ, and 990-N filings for tax years beginning on or after 1 January 2025, provided their only US-source income comes from tournament participation. 

RF Report

The US Internal Revenue Service (IRS) has issued Revenue Procedure 2026-28, exempting certain foreign FIFA member associations that participated in the FIFA World Cup 2026 from filing  US Federal Form 990 (Return of Organisation Exempt From Income Tax) for tax years in which they have no US-source or effectively connected income other than income earned from participating in the tournament.

Under these rules, qualifying foreign participating member associations (PMAs) are relieved from filing annual information returns provided their US-sourced income is derived solely from tournament participation. This exception covers various financial gains, such as FIFA prize money and related promotional revenue, for tax years starting in 2025.

By exercising its discretionary authority, the Treasury Department aims to simplify tax compliance for teams whose global operations are otherwise unrelated to the domestic tax system.

The Treasury and IRS identified three primary reasons why annual Form 990 filings for foreign PMAs are unnecessary:

  1. Discrete and time-limited activity: Foreign PMAs are not expected to generate recurring US-source or effectively connected income (ECI) due to the temporary nature of the tournament.
  2. Membership-based presence: A PMA’s physical or economic presence in the United States stems from its membership in FIFA and tournament participation (along with incidental financial and administrative setups), rather than independent commercial activity in the US.
  3. Disproportionate compliance burden: Form 990 requires an organisation to report its worldwide operations. Requiring foreign PMAs to file would create a heavy administrative burden that far outweighs the informational benefit to the IRS, given that PMAs operate overwhelmingly outside the US.

Qualification requirements

To be eligible for filing relief under RP 2026-28 for a given taxable year, a foreign FIFA association must meet four criteria:

  • World Cup participation: The national team of the foreign PMA must actively compete in the FIFA World Cup 2026.
  • Foreign entity status: The organisation must qualify as a foreign entity (not created or organised in the US or under US law).
  • Tax-exempt status: The organisation must substantively qualify for federal tax exemption under IRC section 501(a).
  • Income limitations: The PMA must have no gross income from US sources and no gross income effectively connected with a US trade or business, other than income directly related to competing in the tournament.

Scope of relief and covered forms

For qualifying foreign PMAs, RP 2026-28 provides the following relief on an annual, taxable-year basis:

  • Form 990/990-EZ: Qualifying FIFA member associations are exempt from filing annual Form 990 or Form 990-EZ.
  • Form 990-N: They are also exempt from filing the annual Form 990-N (e-Postcard).
  • Automatic relief: The exemption applies automatically, even without an IRS determination letter recognising Section 501(a) tax-exempt status.

Qualifying income vs. non-qualifying income

The revenue procedure establishes clear boundaries regarding permissible income during tournament years:

  • Relief retained: Qualifying FIFA member associations keep the filing exemption if their only US-related income is directly tied to FIFA World Cup 2026 participation (e.g., FIFA prize money or tournament-related sponsorship income).
  • Relief lost: The exemption does not apply if the association earns any US-source or effectively connected income unrelated to the World Cup, requiring it to meet normal Form 990/990-EZ filing obligations unless another exception applies.

Explicit inclusions & statutory exclusions

The filing relief applies only to qualifying FIFA participating member associations and excludes private foundations and section 509(a)(3) supporting organisations. It is limited to organisational information return filings and does not affect the US tax, withholding, employment tax, treaty, or state and local tax obligations of individual players, coaches, contractors, or support staff.

Revenue Procedure 2026-28 took effect on 24 July 2026 and applies to taxable years beginning on or after 1 January 2025.