FIFA World Cup 990 Relief: Rev. Proc. 2026-28
The 2026 FIFA World Cup will be played across the United States, Canada, and Mexico, and it drags 48 foreign national football federations into contact with the U.S. tax system. Many of those federations are foreign tax-exempt organizations that would normally face a U.S. Form 990 filing question the moment they earn a dollar of U.S.-source income. In July 2026 the IRS narrowed that question with FIFA World Cup 990 relief in Rev. Proc. 2026-28.
At SW Accounting & Consulting Corp we advise Los Angeles clients on U.S. filings for foreign tax-exempt organizations, and questions about this specific IRS pronouncement have arrived quickly. Here is what the revenue procedure actually does, who it covers, and what still gets you a filing obligation.
What is FIFA World Cup 990 relief under Rev. Proc. 2026-28? ⚽
It is a narrowly-tailored IRS exception that relieves eligible foreign FIFA member associations from filing Form 990 for a tax year in which their only U.S. gross income relates to competing in the 2026 FIFA World Cup.
The IRS has statutory authority under IRC §6033(a)(3)(B) to relieve exempt organizations from the annual Form 990 filing when it decides those filings are not necessary to efficient tax administration. Using that authority, Rev. Proc. 2026-28 tells a foreign FIFA participating member association (PMA) — the national federation whose team plays in the tournament — that it does not have to file Form 990 (or Form 990-EZ) for a taxable year in which it has no U.S.-source gross income (and no gross income effectively connected with a U.S. trade or business) other than income related to competing in the 2026 World Cup.
“Income related to competing in the FIFA World Cup 2026” is illustrated in the guidance as prize money from FIFA and promotional income received from third persons related to the association’s participation in the tournament. Everything outside that lane still counts as ordinary U.S. income for filing-threshold purposes.
Which organizations qualify — and which do not? 🏳️
The relief targets a specific slice: foreign, §501(a)-exempt member associations that are not private foundations and not §509(a)(3) supporting organizations.
Reading the revenue procedure closely, an organization is inside the relief if all of the following are true for the taxable year:
- It is a foreign organization — i.e., not one described in IRC §170(c)(2)(A).
- It is a FIFA member association competing in the 2026 FIFA World Cup (a “participating member association” or PMA).
- It is exempt from federal income tax under §501(a), whether or not it has applied for or received an IRS determination letter.
- It is not a private foundation, and not an IRC §509(a)(3) supporting organization.
- It has no U.S.-source gross income (and no effectively-connected income) for that year other than income related to competing in the 2026 World Cup.
Because §6033(a)(3)(B) does not reach §509(a)(3) organizations, the IRS could not have extended the pass to them even if it had wanted to — that limit comes from the Pension Protection Act of 2006. Domestic U.S. tax-exempt organizations are not the subject of the guidance at all.
Does the e-Postcard (Form 990-N) still have to be filed? 📮
No. A PMA that qualifies for the Form 990 exception is also relieved from the §6033(i) Form 990-N e-Postcard requirement for that year.
The IRS specifically notes that §6033(i)’s e-Postcard obligation does not apply to an organization inside this exception because the exception itself is measured by gross income rather than gross receipts. In plain English: if you are excused from filing Form 990 under Rev. Proc. 2026-28 for a year, you are excused from Form 990-N for the same year — you do not have to file anything on the exempt-org information-return track.
When does the relief take effect, and what does it change? 📅
The revenue procedure is effective July 24, 2026 and applies to taxable years beginning on or after January 1, 2025 — and it amplifies (rather than replaces) the older foreign-organization exception in Rev. Proc. 2011-15.
Rev. Proc. 2011-15 already relieves certain foreign organizations from filing Form 990 when their annual U.S.-source gross receipts are normally not more than $50,000 and they have no significant U.S. activity. That older exception used a gross-receipts test. Rev. Proc. 2026-28 does not replace it — it “amplifies” it — but the new World Cup-specific pass uses a stricter gross income test and is limited to PMAs.
The IRS gave three reasons for the World Cup carve-out in the guidance itself:
- Foreign PMAs are not expected to have recurring U.S.-source or effectively-connected income given the discrete, time-limited nature of the 2026 World Cup.
- Their U.S. presence is a function of FIFA membership and tournament participation, not independent U.S. activity.
- Form 990 requires reporting worldwide operations, so requiring it here would impose a compliance burden disproportionate to the informational value.
How the FIFA World Cup 990 relief compares to older exceptions 📊
| Provision | Who it covers | Test used | Also waives 990-N? |
|---|---|---|---|
| Rev. Proc. 2011-15 | Foreign organizations (non-PF) generally | Gross receipts normally ≤ $50,000 + no significant U.S. activity | e-Postcard rules still apply per §6033(i) |
| Rev. Proc. 2026-28 | Foreign FIFA PMAs (non-PF, non-§509(a)(3)) | Gross income — only World Cup-related U.S. income allowed | Yes — 990-N not required for the same year |
What should a foreign PMA (or its advisor) do now? ✅
Confirm the entity’s classification, walk through every U.S. dollar in the relevant tax year, and paper the file so the exception is defensible on examination.
- Verify §501(a) status. The exception applies whether or not the PMA has an IRS determination letter, but you still need to be comfortable it is in fact §501(a) exempt and neither a private foundation nor a §509(a)(3) supporting organization.
- Inventory U.S. gross income for the year. Isolate prize money from FIFA and promotional income tied to World Cup participation from everything else. Any other U.S.-source or effectively-connected income disqualifies the year.
- Apply the source rules correctly. The revenue procedure uses IRC §§861–865 to source income other than gifts, grants, contributions, and membership fees, and Treas. Reg. §53.4948-1(b) for those items.
- Document the position. Keep contemporaneous records — the FIFA prize schedule, promotional contracts, any other U.S. activity — so you can show that the tax year fits inside Section 4.01 of Rev. Proc. 2026-28.
- Do not assume 2027 is the same. The exception applies year-by-year. A federation with U.S. income only in the 2026 tax year still needs to reassess for 2025 (retroactive coverage) and any future year in which it operates in the U.S.
📌 Key Takeaways
- Rev. Proc. 2026-28 waives Form 990 for eligible foreign FIFA member associations in years where their only U.S. income is World Cup-related.
- Covers §501(a) exempt PMAs — excludes private foundations and §509(a)(3) supporting organizations.
- Also waives the Form 990-N e-Postcard for the same year.
- Any other U.S.-source or ECI in the year kills the exception for that year.
- Effective July 24, 2026; applies to tax years beginning on or after January 1, 2025.
Frequently Asked Questions ❓
Q. What exactly is a “participating member association” under Rev. Proc. 2026-28?
It is a FIFA member association whose national team is competing in the 2026 FIFA World Cup — the national football federation itself, not the players or a domestic sponsor.
Q. Does the exception cover prize money and endorsement income earned in the U.S.?
Yes, if that income is tied to competing in the 2026 World Cup. The guidance illustrates the covered category as FIFA prize money and promotional income from third persons related to the PMA’s participation in the tournament.
Q. What happens if the federation earns other unrelated U.S. income in the same year?
The exception is off for that tax year. The PMA must then file Form 990 (or 990-EZ) or, if applicable, the 990-N e-Postcard, unless a different filing exception applies.
Q. Do U.S. tax-exempt organizations get any relief from this revenue procedure?
No. Rev. Proc. 2026-28 addresses foreign PMAs. Domestic §501(c) organizations file under the ordinary Form 990 rules; a U.S. host committee, U.S. sponsor, or U.S. charitable organization is not the subject of the guidance.
Q. Does the PMA need an IRS determination letter to rely on the exception?
No. The revenue procedure states the exception applies whether or not the organization has applied for or received recognition of exemption under §501(a). But it still must actually meet the §501(a) requirements.
Q. How does this interact with Rev. Proc. 2011-15?
Rev. Proc. 2026-28 amplifies Rev. Proc. 2011-15 rather than replacing it. Foreign organizations that meet the older $50,000 gross-receipts test can still use that route; the new procedure adds a PMA-specific pass for the World Cup.
If your organization is a foreign tax-exempt entity with U.S. activity — World Cup-related or otherwise — and you want to confirm which annual filing rules apply, contact SW Accounting & Consulting Corp. Primary sources: IRS Rev. Proc. 2026-28, IRS Rev. Proc. 2011-15, IRC §6033, and IRC §501.
