IRS Relieves FIFA World Cup 2026 Participating Member Associations from Form 990 Filing Requirement

IRS Grants Relief to Foreign FIFA World Cup Teams: No Form 990 Required for 2026 Participants

The IRS issued Revenue Procedure 2026-28 on August 7, 2026, granting foreign FIFA Participating Member Associations (PMAs) competing in the 2026 FIFA World Cup a temporary exemption from filing Form 990-series annual information returns for tax years in which they derive no U.S.-sourced income other than earnings directly tied to World Cup participation. This relief, anchored in the IRS’s discretionary authority under § 6033(a)(3)(B), reduces compliance burdens for over 48 foreign national football federations and their affiliated entities by eliminating the need for costly annual filings when their U.S. financial footprint is limited to tournament-related revenue. The exception explicitly excludes private foundations and supporting organizations under § 509(a)(3), ensuring the relief targets only the narrow cohort of foreign PMAs whose U.S. income is confined to World Cup-related activities. By amplifying Rev. Proc. 2011-15, the IRS signals a targeted, event-specific approach to exempt organization compliance that prioritizes administrative efficiency over rigid enforcement in the context of a high-profile global sporting event.

The Rule: How the IRS Exempts FIFA PMAs from Annual Filings

Rev. Proc. 2026-28 exercises the IRS’s discretion under § 6033(a)(3)(B) to relieve foreign participating member associations (PMAs) of the Fédération Internationale de Football Association (FIFA) competing in the 2026 FIFA World Cup from the requirement to file a Form 990-series annual information return. This exemption applies only if the foreign PMA meets three specific conditions: it must be (1) exempt from federal income tax under § 501(a), (2) not a private foundation or a § 509(a)(3) supporting organization, and (3) have no gross income from sources within the United States or effectively connected with the conduct of a trade or business within the United States other than income related to competing in the FIFA World Cup 2026. The relief is explicitly limited to taxable years beginning on or after January 1, 2025, and does not extend to organizations that generate U.S.-sourced income outside the narrow scope of World Cup-related activities.

The statutory authority for this relief derives from § 6033(a)(3)(B), which grants the Secretary of the Treasury (or delegate) discretion to waive the annual filing requirement for exempt organizations when such filings are not necessary to the efficient administration of the internal revenue laws. This discretionary authority was delegated to the Commissioner of Internal Revenue under § 1.6033-2(g)(6), which permits the IRS to relieve organizations from filing Form 990 if the Commissioner determines that the filing is not essential for tax administration. The revenue procedure clarifies that the IRS’s exercise of this authority in this context is justified by the discrete, time-limited nature of the FIFA World Cup 2026 and the minimal U.S. presence of participating PMAs during the event. The relief is further circumscribed by the exclusion of private foundations and supporting organizations under § 509(a)(3), ensuring that only foreign PMAs with negligible U.S. operations beyond World Cup participation qualify for the exception.

Why the IRS Acted: Context and Justification for the Relief

The IRS’s decision to exempt foreign Private Management Associations (PMAs) participating in the FIFA World Cup 2026 from filing Form 990 under § 6033(a)(3)(B) is rooted in the agency’s longstanding discretionary authority to waive annual information return requirements for exempt organizations when such filings are deemed unnecessary to the efficient administration of the internal revenue laws. This authority traces back to the Pension Protection Act of 2006 (PPA), Public Law 109-280 (120 Stat. 780), which amended § 6033(a)(3)(B) to remove the Secretary’s discretion to relieve supporting organizations under § 509(a)(3) from filing requirements. The PPA’s restriction on supporting organizations reflects Congress’s intent to tighten oversight of entities that, while technically exempt, often operate with limited public accountability compared to traditional public charities. The IRS’s current relief for FIFA World Cup PMAs thus operates within a carefully circumscribed framework that excludes supporting organizations entirely, ensuring compliance with the PPA’s legislative boundaries.

The IRS’s discretion under § 6033(a)(3)(B) is delegated to the Commissioner via Treas. Reg. § 1.6033-2(g)(6), which empowers the agency to waive filing requirements when the organization’s activities or financial profile render such filings redundant or overly burdensome. This regulatory authority was first operationalized in Rev. Proc. 2011-15, 2011-3 I.R.B. 322, which established a blanket exception for foreign organizations (excluding private foundations) with annual gross receipts not exceeding $50,000 from U.S. sources and no significant U.S. activity. Rev. Proc. 2011-15’s criteria—particularly the $50,000 threshold and the exclusion of U.S. source income—were designed to target small, low-risk foreign entities unlikely to generate meaningful tax compliance concerns. The revenue procedure further clarified that the source of an organization’s income is determined by § 53.4948-1(b) for gifts, grants, contributions, or membership fees and by §§ 861–865 for other income types, ensuring consistency with the Code’s broader sourcing rules.

The IRS’s justification for extending this relief to FIFA World Cup PMAs hinges on three discrete factors outlined in the revenue procedure. First, the agency determined that such PMAs are not expected to have recurring income from U.S. sources or income effectively connected with a U.S. trade or business, given the discrete, time-limited nature of the event. The World Cup’s compressed timeline—spanning June to July 2026—minimizes the likelihood of sustained U.S. operations beyond the event itself, reducing the need for ongoing monitoring through Form 990 filings. Second, the IRS noted that the presence of these PMAs in the United States is incidental to their participation in FIFA and the World Cup, including administrative and financial arrangements directly tied to the event. This contrasts with organizations that maintain independent U.S. operations, where Form 990 filings serve a clear oversight function. Finally, the agency concluded that requiring Form 990 filings would impose a disproportionate compliance burden relative to the informational value provided. The revenue procedure explicitly states that Form 990’s requirement to report “the entirety of [an organization’s] worldwide operations” is unnecessary for PMAs whose activities are overwhelmingly foreign in nature during the taxable years in question.

The IRS’s exercise of discretion in this context is further circumscribed by the exclusion of private foundations (§ 509(a)(1)) and supporting organizations (§ 509(a)(3)), as mandated by the PPA. Private foundations are excluded due to their inherent complexity and higher risk of tax abuse, while supporting organizations are barred by statute. The revenue procedure clarifies that the relief applies only to foreign PMAs exempt under § 501(a) (other than private foundations or supporting organizations) for taxable years in which they have no gross income from U.S. sources or effectively connected income, except for income directly related to World Cup participation (e.g., prize money or promotional income). This narrow scope ensures that the exception does not undermine the IRS’s broader enforcement priorities, particularly in areas where tax compliance risks are more pronounced.

The IRS’s reasoning aligns with its broader enforcement posture toward foreign exempt organizations, which has evolved significantly in recent years. The agency has increasingly focused on digital income, U.S. nexus, and state-level tax obligations as areas of heightened risk, as evidenced by IRS Memorandum LB&I-04-0722-0015 (2022), which targeted foreign NGOs with unreported U.S. rental income. The FIFA World Cup relief, by contrast, reflects a targeted, event-specific exemption that balances administrative efficiency with the realities of temporary, low-risk foreign participation. The IRS’s decision also dovetails with Rev. Proc. 2011-15, which it amplifies in this context, reinforcing the consistency of the agency’s approach to foreign exempt organizations with minimal U.S. ties. By limiting the relief to the discrete circumstances of the World Cup, the IRS avoids setting a broader precedent that could erode compliance standards for other foreign entities with more substantial U.S. operations.

Scope and Exceptions: Who Qualifies and Who Doesn’t

Rev. Proc. 2026-28’s relief is narrowly tailored to the discrete circumstances of the FIFA World Cup 2026, excluding broader applications that could otherwise erode compliance standards for foreign exempt organizations with more substantial U.S. operations. The revenue procedure explicitly limits its scope to foreign private management associations (PMAs) competing in the FIFA World Cup 2026 that are exempt from federal income tax under § 501(a)—excluding private foundations under § 509(a)(1) and supporting organizations under § 509(a)(3). This exclusion ensures that the relief does not inadvertently benefit entities with the structural complexity or operational scale that typically warrant annual Form 990 filings.

The relief applies only to taxable years in which the foreign PMA has no gross income from sources within the United States or gross income effectively connected with the conduct of a trade or business within the United States, other than income related to competing in the FIFA World Cup 2026. This condition reflects the IRS’s intent to exempt organizations whose U.S. ties are incidental to the event itself, rather than those with ongoing or substantial U.S. operations. The exclusion of U.S.-sourced income unrelated to the World Cup aligns with § 861, which defines U.S. source income, and § 864, which governs effectively connected income, ensuring that the relief does not extend to organizations with meaningful U.S. economic engagement.

The exception applies regardless of whether the organization has applied for or received recognition of exemption under § 501(a), removing administrative barriers for foreign PMAs that may not have pursued formal U.S. tax-exempt status. This provision acknowledges the impracticality of requiring formal recognition for temporary, low-risk participation in a single event. However, the relief is explicitly time-bound, applying to taxable years beginning on or after January 1, 2025, which ensures the IRS does not set a precedent for broader, open-ended exemptions for foreign organizations with minimal U.S. ties. This temporal limitation reinforces the IRS’s broader policy of avoiding precedential erosion of compliance standards for foreign exempt organizations with more substantial U.S. operations.

Procedural Relief: How the Exception Works in Practice

The procedural mechanics of Rev. Proc. 2026-28’s relief are explicitly delineated in Section 4, which operates as a conditional exemption rather than an absolute waiver. A foreign participating member association (PMA) competing in the 2026 FIFA World Cup is relieved from filing Form 990 only if it meets the gross income threshold specified in section 3—namely, having no gross income from sources within the United States or effectively connected with the conduct of a trade or business within the United States, other than income related to participation in the FIFA World Cup 2026. This condition is not a blanket exemption; it is contingent upon the absence of U.S.-sourced or effectively connected income during the taxable year. The IRS explicitly states that if a foreign PMA fails to satisfy these conditions in any taxable year, it is required to file the annual information return or submit the annual notice for such taxable year, unless another filing exception applies under § 6033(a)(1) or § 6033(i). This ensures that the relief remains time-bound and event-specific, reinforcing the IRS’s broader policy of avoiding precedential erosion of compliance standards for foreign exempt organizations with more substantial U.S. operations.

The relief under section 4.01 applies regardless of whether the organization has applied for or received recognition of exemption under § 501(a), provided it meets the gross income test. The IRS clarifies that the exception is based on gross income, not gross receipts, which is a critical distinction. Section 6033(i) requires organizations relieved from filing Form 990 under § 6033(a)(3)(B) by reason of their gross receipts to file an annual notice via Form 990-N e-Postcard. However, Rev. Proc. 2026-28 explicitly states that § 6033(i) does not apply to foreign PMAs covered by this revenue procedure because the exception is not predicated on gross receipts but on the absence of U.S.-sourced or effectively connected income. This procedural nuance prevents foreign PMAs from inadvertently triggering the e-Postcard requirement, which would otherwise impose an additional compliance burden disproportionate to their limited U.S. activities.

The annual notice requirement under § 1.6033-6 remains relevant for organizations that do not qualify for relief under Rev. Proc. 2026-28. Section 1.6033-6 of the Treasury Regulations governs the annual notice requirement for small exempt organizations, which is typically satisfied by filing Form 990-N. While Rev. Proc. 2026-28 relieves qualifying foreign PMAs from this requirement, organizations that fail to meet the conditions in any taxable year must comply with the general filing rules under § 6033(a)(1) and § 6033(i). The IRS’s discretionary authority under § 6033(a)(3)(B) is not a substitute for annual compliance but rather a targeted relief mechanism for low-risk, temporary activities. This ensures that the IRS maintains visibility into organizations that may otherwise fall below standard filing thresholds but still engage in U.S. activities.

Amplifying Prior Guidance: How Rev. Proc. 2026-28 Builds on Rev. Proc. 2011-15

Rev. Proc. 2026-28 does not alter the foundational framework of Rev. Proc. 2011-15 but extends its relief mechanism to a new, highly specific fact pattern: foreign Private Management Associations (PMAs) participating in the 2026 FIFA World Cup. The IRS’s use of the term "amplified" in Section 5 of Rev. Proc. 2026-28 is not incidental; it reflects a deliberate choice to preserve the prior guidance’s structure while grafting on a targeted exception for FIFA-related entities. Under the IRS’s defined terminology in the Definition of Terms section, "amplified" means that "no change is being made in a prior published position, but the prior position is being extended to apply to a variation of the fact situation set forth therein." Here, the "prior position" is Rev. Proc. 2011-15’s discretionary relief for foreign organizations with gross receipts of $50,000 or less and no significant U.S. activity, while the "variation" is the FIFA PMAs’ exemption tied to gross income rather than receipts and conditioned on World Cup participation.

Rev. Proc. 2011-15, issued in 2011, provided relief under § 6033(a)(3)(B) for foreign organizations with gross receipts of $50,000 or less (adjusted for inflation to $56,000 for 2024) and no U.S.-sourced gross income. The relief allowed such organizations to avoid filing Form 990, 990-EZ, or 990-PF, relying instead on the IRS’s discretionary authority to waive annual filing requirements. This was grounded in the IRS’s recognition that small foreign organizations with minimal U.S. engagement posed low compliance risk and administrative burden. The procedural mechanism required organizations to self-certify their eligibility, with the IRS reserving the right to revoke the exemption retroactively if the organization failed to meet the conditions in any taxable year. Failure to comply triggered the general filing rules under § 6033(a)(1) and § 6033(i), including potential penalties under § 6652(c)(1)(A) for late or non-filing.

Rev. Proc. 2026-28 amplifies this framework by introducing a parallel but distinct relief mechanism for FIFA PMAs. Unlike Rev. Proc. 2011-15, which hinged on gross receipts and the absence of U.S. income, Rev. Proc. 2026-28 bases eligibility on gross income and ties the exemption to participation in the 2026 FIFA World Cup. The IRS’s decision to use "gross income" rather than "gross receipts" reflects a narrower, event-specific scope: FIFA PMAs are expected to generate significant gross income during the World Cup but are unlikely to have ongoing U.S. operations or recurring U.S. income outside the event. This distinction ensures that the relief is temporary and contingent, aligning with the IRS’s broader policy of targeting low-risk, short-term activities. The IRS’s discretionary authority under § 6033(a)(3)(B) remains the operative legal basis, but the factual predicate has been recalibrated to address the unique circumstances of the World Cup.

The amplification also clarifies the IRS’s intent to avoid duplicative or unnecessary filings for organizations that, while engaged in U.S. activities during the World Cup, do not present the same compliance risks as organizations with ongoing U.S. operations. By extending the prior position to a new fact pattern—FIFA PMAs—without altering the underlying principles of Rev. Proc. 2011-15, the IRS maintains consistency in its enforcement approach while adapting to the exigencies of a global sporting event. This approach ensures that practitioners can rely on the familiar contours of Rev. Proc. 2011-15’s relief mechanism while recognizing the tailored adjustments made for FIFA-related entities. The IRS’s careful use of "amplified" signals that this is an extension, not a revision, of prior guidance, preserving the integrity of the original framework while addressing a novel compliance challenge.

Key Definitions: Decoding the IRS’s Technical Terms

The IRS’s relief for FIFA World Cup PMAs hinges on precise tax terminology that practitioners must parse to advise clients accurately. These terms define the boundaries of exempt status, income sourcing, and compliance obligations under Rev. Proc. 2026-28. The IRS’s careful use of "amplified" in this context signals continuity with prior guidance, but practitioners must still navigate the nuances of each concept to avoid misapplication.

§ 501(a) tax-exempt status refers to the foundational provision in the Internal Revenue Code that exempts qualifying organizations from federal income tax. This section operates as a gateway: an entity must first meet § 501(a) to qualify for exempt status under specific paragraphs like § 501(c)(3) or § 501(c)(6). The IRS’s relief in Rev. Proc. 2026-28 explicitly applies to foreign PMAs exempt under § 501(a), excluding private foundations and § 509(a)(3) supporting organizations. The court in Bob Jones University v. United States, 461 U.S. 574 (1983), underscored that § 501(a) is not self-executing; organizations must demonstrate compliance with the specific requirements of their claimed exemption category.

Private foundations vs. public charities represent distinct subclasses of § 501(c)(3) organizations, each with divergent compliance burdens. Private foundations, defined in § 509(a), are typically funded by a single source or small group of donors and face stricter operational rules, including excise taxes on investment income under § 4940. Public charities, in contrast, derive broad public support under § 509(a)(1) or (2) and are subject to less onerous reporting requirements. Rev. Proc. 2026-28 excludes private foundations from its relief, reflecting their heightened compliance obligations under § 6033(a)(1).

§ 509(a)(3) supporting organizations are a specialized subset of § 501(c)(3) entities designed to support one or more public charities. The IRS’s exclusion of these organizations from the FIFA relief underscores their structural complexity and the potential for abuse. The Tax Court in Foundation for the People of the Philippines v. Commissioner, T.C. Memo. 2016-145, emphasized that supporting organizations must demonstrate operational independence from disqualified persons to avoid reclassification as private foundations. Rev. Proc. 2026-28’s exclusion aligns with the IRS’s longstanding skepticism toward supporting organizations that fail to meet the "integrated test" under § 509(a)(3)(B).

Gross income from U.S. sources is governed by the sourcing rules in §§ 861–865, which allocate income based on its geographic origin. For foreign organizations, § 53.4948-1(b) provides that gifts, grants, contributions, or membership fees received from a United States person are deemed U.S. source income. The IRS’s reliance on these sections in Rev. Proc. 2026-28 reflects its broader enforcement focus on foreign entities with U.S. funding streams. The Tax Court in United States v. Bank of New England, 821 F.2d 844 (1st Cir. 1987), affirmed that the sourcing rules are strictly applied to prevent tax avoidance, particularly in cases involving foreign entities with U.S. donors.

Effectively connected income refers to income derived from a U.S. trade or business under § 864(c). Unlike passive income subject to FDAP withholding, ECI is taxed at graduated rates under § 1 or § 11, depending on the entity’s structure. Rev. Proc. 2026-28’s exclusion of ECI from the relief mechanism ensures that foreign PMAs with U.S. operations remain subject to U.S. tax jurisdiction. The IRS’s position in Revenue Ruling 75-147, 1975-1 C.B. 103, clarified that income from activities like broadcasting or sponsorships in the U.S. constitutes ECI, reinforcing the need for compliance.

Form 990-N e-Postcard is the annual filing requirement for small tax-exempt organizations under § 6033(i). Organizations with gross receipts of $50,000 or less must file this simplified notice to maintain exempt status. Rev. Proc. 2026-28 explicitly relieves FIFA PMAs of this requirement when they meet the income sourcing criteria, but practitioners must remain vigilant about the § 6033(i) threshold. The IRS’s Announcement 2020-12 highlighted the consequences of non-filing, including automatic revocation of exempt status after three consecutive years of non-compliance.

United States person is defined in § 7701(a)(30) to include citizens, residents, domestic corporations, partnerships, estates, and trusts subject to U.S. court supervision. This definition is critical for determining whether income is sourced to the U.S. under § 53.4948-1(b). The IRS’s Notice 2023-10 emphasized that foreign organizations receiving funds from U.S. persons must treat those funds as U.S. source income, regardless of the recipient’s location.

United States is defined in § 7701(a)(9) as the 50 states and the District of Columbia. This geographic limitation is pivotal for sourcing rules under §§ 861–865, as income derived from activities outside these boundaries is not considered U.S. source income. The IRS’s Revenue Ruling 80-280, 1980-2 C.B. 192, confirmed that income from U.S. territories (e.g., Puerto Rico) is not treated as U.S. source income for foreign organizations, though practitioners must distinguish between territorial and state-level sourcing.

What This Means for Tax Practitioners and Foreign Exempt Organizations

Rev. Proc. 2026-28 marks a targeted but consequential expansion of the IRS’s discretionary relief for foreign exempt organizations, particularly those participating in the 2026 FIFA World Cup. For tax practitioners advising foreign participants, the most immediate implication is the elimination of the annual Form 990 filing requirement for FIFA PMAs, provided they meet the gross receipts threshold and have no U.S.-sourced income. This relief, effective July 24, 2026, and applicable to taxable years beginning on or after January 1, 2025, significantly reduces compliance burdens for qualifying organizations but introduces nuanced obligations that demand careful structuring and documentation.

The relief hinges on the absence of U.S.-sourced income, a concept defined under § 861(a), which enumerates categories of income treated as U.S. source, including interest, dividends, rents, royalties, and income from services performed in the United States. For FIFA PMAs, income from ticket sales, broadcasting rights, and sponsorships tied to U.S. events would typically constitute U.S. source income under § 861(a)(3) and § 861(a)(4), triggering potential filing obligations unless an exception applies. The IRS’s decision to waive the Form 990 requirement for FIFA PMAs reflects a recognition of the administrative burden associated with event-specific compliance, but it does not absolve organizations of the need to accurately determine and disclose income sources. Practitioners must therefore advise clients to rigorously track income streams, distinguishing World Cup-related revenue from other U.S. activities to avoid misclassification.

The procedural relief outlined in Rev. Proc. 2026-28 amplifies prior guidance under Rev. Proc. 2011-15, which established streamlined procedures for exempt organizations, including foreign entities, to correct defects in filings or governing documents. However, Rev. Proc. 2026-28 introduces a geographically and event-specific limitation, applying only to FIFA PMAs for the 2026 World Cup. This precedent sets a potential blueprint for future event-based exemptions, particularly for major international sporting events or cultural festivals hosted in the U.S. Tax practitioners should monitor whether the IRS extends similar relief for other events, such as the 2028 Summer Olympics in Los Angeles, given the agency’s demonstrated willingness to tailor compliance burdens to event-specific contexts.

For foreign exempt organizations beyond FIFA PMAs, the broader implications of Rev. Proc. 2026-28 are instructive. The IRS’s willingness to exercise discretion under § 6033(a)(3)(B)—which permits waivers of filing requirements for small exempt organizations—suggests a more flexible approach to compliance for organizations with minimal U.S. ties. However, the relief remains contingent on the absence of U.S.-sourced income, a standard reinforced by Treas. Reg. § 1.6033-2(g)(1)(iv), which requires organizations to self-certify their income sources annually. Practitioners must emphasize to clients that even incidental U.S. income, such as rental income from a U.S. property or royalties from a U.S. patent, would disqualify them from relief under Rev. Proc. 2026-28 and potentially trigger penalties under § 6652(c)(1)(A), which imposes a $20-per-day penalty (capped at $10,000 or 5% of gross receipts) for failure to file required returns.

The challenge for tax practitioners lies in the determination of U.S. source income, particularly for organizations engaged in digital activities or remote services. The IRS’s recent guidance, including IRS Notice 2023-10, clarified that income from services performed by remote workers in the U.S. constitutes U.S. source income, a rule that could ensnare foreign NGOs with U.S.-based employees. For FIFA PMAs, the risk is amplified by the event’s multi-jurisdictional nature, with activities spanning the U.S., Canada, and Mexico. Practitioners must advise clients to conduct a jurisdictional income analysis, separating income derived from U.S. activities (e.g., games played in U.S. stadiums) from income sourced to Canada or Mexico, where different tax rules may apply.

The effective date of Rev. Proc. 2026-28—July 24, 2026—coincides with the lead-up to the 2026 FIFA World Cup, providing organizations with a narrow window to assess their eligibility and adjust their compliance strategies. Tax practitioners should proactively engage with clients to review their income structures, ensuring that any U.S.-sourced income is accurately identified and reported, even if the organization qualifies for the Form 990 exemption. For organizations that do not meet the relief criteria, the IRS’s approach underscores the importance of timely filings and accurate disclosures to avoid penalties or revocation of exempt status.

Looking ahead, Rev. Proc. 2026-28 signals a broader trend in the IRS’s administration of exempt organization compliance: a willingness to grant targeted relief for event-specific scenarios while maintaining rigorous standards for income sourcing and disclosure. Tax practitioners should anticipate further refinements to the IRS’s discretionary authority under § 6033(a)(3)(B), particularly as digital commerce and remote work blur traditional boundaries of U.S. source income. The agency’s approach to FIFA PMAs may also foreshadow increased scrutiny of other foreign exempt organizations with U.S. operations, reinforcing the need for proactive compliance and robust record-keeping. In this evolving landscape, practitioners must balance the benefits of relief with the risks of misclassification, ensuring that their clients navigate the IRS’s expectations with precision.