FIFA Income Exempt from Reporting Requirements

Cross References

  • Rev. Proc. 2026-28

Exempt organizations are generally required to file an annual information return such as Form 990, 990-EZ, or 990-PF, Return of Private Foundation or Section 4947(a)(1) Trust Treated as Private Foundation.

Gifts, grants, contributions, or membership fees received directly or indirectly by a foreign organization from a United States person are from sources within the United States.

Rev. Proc. 2026-28 states that the Secretary of Treasury has determined that the filing of Form 990 by any foreign participating member association (PMA) whose national teams are competing in the Federation International Football Association (FIFA) World Cup 2026 is not necessary to the efficient administration of the Internal Revenue Laws for the following reasons. 1) Such PMAs are not expected to have recuring income from United States sources or

recurring income effectively connected with the conduct of a United States trade or business given the discrete time-limited nature of the FIFA World Cup 2026.

2) The presence of such PMAs in the United States is a function of their membership in

FIFA and participation in the FIFA World Cup 2026 rather than independent activity in the United States, and

3) Requiring such PMAs to file Form 990 would impose a compliance burden dispropor-

tionate to the informational value provided by the filings because Form 990 requires organizations to report the entirety of their worldwide operations, whereas the revenue and activities of each foreign PMA are overwhelmingly expected to be foreign in nature in those tax years in which the PMA is exempted from filing.

As such, the Secretary of the Treasury has determined that any foreign PMA competing in the FIFA World Cup 2026 is exempt from federal income tax under IRC section 501(a) (other than a private foundation or a section 509(a)(3) supporting organization), for any tax year in which it 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 exception applies whether or not the organization has applied for or received recognition of exemption under IRC section 501(a). Thus, such PMA described above is exempt from filing Form 990 or from having to submit a Form 990-N e-Postcard for such tax year.