IRS waives Form 990 filing for qualifying foreign World Cup teams
Foreign soccer associations that qualify and compete in the 2026 FIFA World Cup do not need to file Form 990 or Form 990-N for a tax year if their only U.S.-related income comes from taking part in the tournament.
Holding
The IRS used its authority under section 6033(a)(3)(B) to let some foreign FIFA member associations skip the annual Form 990 filing. This relief is for associations whose national teams play in the 2026 FIFA World Cup and whose only U.S. income is from the tournament.
This rule applies to tax years starting on or after January 1, 2025.
Why It Matters
This relief removes a major U.S. reporting requirement for foreign soccer associations whose only U.S. activity is taking part in the 2026 World Cup.
The exception means qualifying associations do not have to file Form 990, Form 990-EZ, or the Form 990-N electronic notice for those years.
This relief does not exempt associations from federal income tax, cover unrelated U.S. activities, or remove other possible tax reporting duties.
The exception is limited. If an association earns other U.S. income or does business in the U.S. outside the World Cup, it must still file the required annual return or notice.
Key Facts
The 2026 FIFA World Cup will have foreign national teams playing matches that are partly hosted in the United States.
Each national team takes part through its FIFA member association. The IRS calls a foreign association whose team plays in the tournament a participating member association, or PMA.
Some foreign PMAs may qualify as tax-exempt under section 501(a). Without this special relief, they would have to file Form 990 and report on their worldwide activities, even if their only U.S. presence is for the World Cup. Filing full Form 990 filings would impose a compliance burden that exceeded the value of the information collected.
This relief started on July 24, 2026, and applies to tax years beginning on or after January 1, 2025.
Organizations Covered
The revenue procedure applies to a foreign PMA that:
Has a national team competing in the 2026 FIFA World Cup.
Qualifies for exemption from federal income tax under section 501(a).
Is not a private foundation.
Is not a section 509(a)(3) supporting organization.
Has no U.S.-source gross income or income effectively connected with a U.S. trade or business, other than income related to participating in the 2026 World Cup.
An association can still qualify even if it has not applied for or received an IRS letter confirming its tax-exempt status.
Income Covered by the Relief
This exception lets a qualifying PMA get income from World Cup participation without having to file Form 990.
The revenue procedure identifies the following examples:
Prize money paid by FIFA.
Promotional income paid by third parties in connection with the association’s participation in the tournament.
Income arising from administrative or financial arrangements necessary or appropriate to facilitate tournament participation.
The relief only applies if the income is tied to World Cup participation. It does not give a general exemption for all U.S. income earned by a foreign soccer association.
Statutory and Regulatory Framework
Section 6033(a)(1) generally requires organizations exempt from federal income tax to file an annual information return, usually Form 990, Form 990-EZ, or Form 990-PF.
Section 6033(a)(3)(B) allows the Treasury Secretary or the Secretary’s delegate to waive the annual filing requirement when the filing is unnecessary for efficient tax administration. Treasury regulations delegate that authority to the IRS Commissioner.
Congress removed that waiver authority for section 509(a)(3) supporting organizations. The IRS therefore cannot extend this relief to those organizations.
Private foundations also remain outside the revenue procedure.
Section 6033(i) generally requires certain organizations excused from filing a full annual return because of low gross receipts to submit Form 990-N, commonly called the e-Postcard. The IRS determined that qualifying PMAs do not have to submit Form 990-N because this exception turns on the nature of their gross income, not merely the amount of their gross receipts.
Source Rules
The revenue procedure relies on existing tax rules to determine whether income comes from U.S. sources.
Gifts, grants, contributions, and membership fees received directly or indirectly from a U.S. person generally count as U.S.-source income under Treasury Regulation section 53.4948-1(b).
Other categories of income are sourced under sections 861 through 865 and the related regulations.
A U.S. person generally includes:
A U.S. citizen or resident.
A domestic partnership.
A domestic corporation.
A nonforeign estate.
Certain trusts subject to U.S. Court supervision and substantial control by U.S. persons.
For this revenue procedure, the term United States includes the 50 states and the District of Columbia.
IRS Rationale
The IRS gave three principal reasons for waiving the filing requirement.
The associations are not expected to earn recurring U.S.-source income or repeatedly conduct a U.S. trade or business. Their U.S. activity arises from a discrete international sporting event.
Their presence in the United States results from FIFA membership and World Cup participation, not from independent or continuing domestic operations.
Form 990 asks for details about an organization’s worldwide operations. For these associations, most activities and revenue are outside the U.S., so filing a full return would be a lot of work for little benefit.
Filing Consequences
A qualifying foreign PMA does not have to file Form 990 or Form 990-EZ for a covered year.
It also does not have to submit Form 990-N for that year.
The relief applies separately to each taxable year. An association must test its eligibility annually.
If tIf the association gets other U.S. income or does business in the U.S. outside the World Cup, it must file the required annual return or notice unless another exception applies.
The revenue procedure addresses only the annual information-return requirement under section 6033.
It does not state that:
World Cup income is excluded from gross income.
Tournament income is exempt from federal income tax.
Foreign players, coaches, employees, contractors, or other individuals receive personal tax relief.
FIFA itself qualifies for the exception.
Domestic soccer organizations qualify for the exception.
Employment tax, withholding, information reporting, or unrelated business income requirements do not apply.
The practical effect is therefore narrower than an exemption from income reporting. In practice, this is not a full exemption from income reporting. It only removes one filing requirement for qualifying foreign tax-exempt associations. Certain foreign organizations are exempt from filing Form 990 when they normally receive no more than $50,000 in annual gross receipts from U.S. sources and have no significant U.S. activity.
The new rule expands on the earlier guidance for World Cup associations. It gives relief even if the association’s U.S. income from the World Cup is over $50,000.
Revenue Procedure 2011-15 remains in effect and is amplified rather than replaced.
The Takeaway
Tax advisers working with foreign national soccer associations should separate tournament-related receipts from all other U.S. income and activity. The filing relief is useful but conditional, and any unrelated U.S. income can restore the annual reporting requirement.