IRS Announces Form 990 Filing Relief for Foreign FIFA World Cup 2026 Teams 

Estimated reading time: 12 minute(s)

Now that the 2026 FIFA World Cup has wrapped up, the IRS has stepped in to clear up a filing question that may have many international soccer federations caught off guard: do foreign national teams need to file a U.S. tax return just for competing here?

The answer, according to newly issued Revenue Procedure 2026-28, is generally no.

Overview of the IRS announcement

Revenue Procedure 2026-28 gives certain FIFA member associations a break from having to file Form 990, Return of Organization Exempt From Income Tax, simply because their national teams are playing in the U.S. during the 2026 World Cup.

Normally, tax-exempt organizations with a U.S. presence are required to file an annual information return under IRC Section 6033(a)(1). But the IRS used its discretionary authority under Section 6033(a)(3)(B) to determine that requiring these foreign associations to file Form 990 wouldn’t meaningfully help the IRS administer the tax code. Their U.S. presence is temporary, tied entirely to tournament participation, and Form 990 would otherwise require reporting on worldwide operations that have little to do with their time in the States. 

This relief is effective July 24, 2026, and applies to tax years beginning on or after January 1, 2025.

Who Qualifies?

The relief is narrowly targeted. To qualify, an organization must be: 

• A foreign FIFA member association whose national team competed in the 2026 FIFA World Cup (referred to in the guidance as a “Participating Member Association,” or PMA)
• Tax-exempt under IRC Section 501(a)

Two categories are specifically carved out and do not qualify for the relief:

• Private foundations
• Section 509(a)(3) supporting organizations 

Notably, the relief applies whether or not the PMA has actually applied for or received formal recognition of its tax-exempt status under Section 501(a).

What exactly is a “PMA”?

A Participating Member Association (PMA) isn’t the squad of players fans watch on the field. It’s the national governing body for soccer in that country. Every country with a team in the World Cup has an official football association that holds membership in FIFA. That governing association is the actual legal entity the IRS guidance is talking about. 

So when the revenue procedure refers to a “foreign PMA competing in the World Cup,” it means: the country’s soccer federation, operating as a tax-exempt organization in its home country, whose team happened to be playing matches on U.S. soil.

What Is the Filing Relief?

Eligible PMAs are relieved from filing Form 990 for any tax year in which they have:

• No gross income from U.S. sources, or
• U.S. -source income that relates only to their participation in the 2026 FIFA World Cup (think prize money from FIFA or promotional income tied to their tournament appearance)

If a PMA’s only connection to U.S. income is the World Cup itself, it’s off the hook for Form 990 that year. It’s worth noting this exception doesn’t hinge on total revenue the way some existing foreign-organization filing exceptions do. It’s based specifically on the source of gross income, not gross receipts.

What About the Form 990-N e-Postcard?

Here’s a detail nonprofit finance teams will appreciate: PMAs that qualify for this relief also don’t need to file a Form 990-N e-Postcard as a substitute. Normally, organizations relieved from Form 990 based on low gross receipts still have to submit that annual e-Postcard notice under Section 6033(i). But since this relief is based on income source rather than receipts, that notice requirement simply doesn’t apply here.

If Circumstances Change

The relief isn’t a blanket exemption for the life of the World Cup. If a PMA has U.S.-source income in a given tax year that goes beyond what’s tied to World Cup competition, it loses the exception for that year and must file Form 990 (or submit the applicable annual notice) as it normally would.

The Bottom Line 

Revenue Procedure 2026-28 amplifies the IRS’s existing foreign-organization filing relief under Rev. Proc. 2011-15, tailoring it specifically to the unique, short-term nature of hosting the World Cup. For most 501(a) tax-exempt national federations whose only U.S. tie is the tournament itself, this means one less compliance headache during a busy year.

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