The IRS has issued new procedural guidance relieving certain foreign FIFA member associations from the requirement to file an annual information return for tax years related to their participation in the 2026 FIFA World Cup. (Rev Proc 2026-28, 7/24/2026)
The new revenue procedure, which amplifies existing guidance, provides a specific filing exception for tax-exempt foreign organizations participating in the recent international soccer tournament.
The IRS reasoned that the compliance burden of filing Form 990, Return of Organization Exempt from Income Tax, which requires reporting worldwide operations, would be disproportionate to the informational value provided by the filings, given the temporary and limited nature of the organizations’ U.S. activities.
General filing rules for exempt organizations
Under IRC § 6033(a)(1), organizations exempt from taxation under IRC § 501(a) are generally required to file an annual information return. But the IRS has the authority under IRC § 6033(a)(3)(B), however, to relieve an organization from this filing requirement if the agency determines it is not necessary for the efficient administration of the tax laws.
For example, in Rev Proc 2011-15, the IRS relieved certain foreign organizations from filing Form 990 if their annual U.S. source gross receipts are normally not more than $50,000 and they have no significant activity in the United States.
New exception for FIFA member associations
The guidance creates a new exception for foreign FIFA participating member associations (PMAs) that competed in this year’s World Cup. Under the new procedure, a PMA will be relieved from the requirement to file Form 990 for any tax year in which it has no gross income from U.S. sources or effectively connected with a U.S. trade or business, other than income that is related to competing in the tournament.
This relief applies whether or not the organization has formally applied for or received recognition of its tax-exempt status from the IRS. The guidance specifies that permitted income includes prize money from FIFA and promotional income from third persons that is related to the foreign PMA’s participation in the World Cup.
Scope and limitations of the relief
The new guidance also specifies that a foreign PMA that qualifies for relief from filing Form 990 is also not subject to the requirement under IRC § 6033(i) to submit a Form 990-N e-Postcard for that tax year. The IRS explained that the Form 990-N requirement does not apply because the exception in the revenue procedure is based on the organization’s gross income, rather than its gross receipts.
If a PMA fails to meet the conditions for the exception in any tax year, it will be required to file the appropriate annual information return or submit the annual notice for that tax year, unless another filing exception applies. The new procedure is effective on July 24, 2026, and applies to tax years beginning on or after January 1, 2025.
For more on discretionary exemptions from information return requirements for exempt organizations, see Checkpoint’s Federal Tax Coordinator 2d ¶ S-2822.
Take your tax and accounting research to the next level with Checkpoint Edge and CoCounsel. Get instant access to AI-assisted research, expert-approved answers, and cutting-edge tools like Advisory Maps and State Charts. Try it today and transform the way you work! Subscribe now and discover a smarter way to find answers.
