IRS Revenue Procedure 2026-28 and World Cup Tax Rules

The two-part test

The reported procedure sets out two central conditions:

  • The association’s team must have competed at the World Cup in the United States.
  • US-source gross income must have been limited to World Cup-related receipts.

That second condition is decisive. Associations with other US-source income do not appear to fall within the exception described in the guidance.

Why the distinction matters

Form 990 is the annual return used by tax-exempt organisations in the US. For an eligible football association, avoiding that filing would remove a specific compliance obligation connected with its World Cup activity.

The relief is therefore narrow rather than a blanket exemption for every national body involved in the tournament. A federation that played in the competition could still face the filing requirement if it generated separate US-source income.

That makes financial classification more important than simply proving tournament participation. Administrators will need to separate receipts connected to the World Cup from other income earned in the United States before deciding whether the exception applies.

A small rule with practical consequences

For football authorities, the measure offers limited relief but also creates a clear administrative test. The central question is not whether an association attended the World Cup, but whether its US-source income stayed within the tournament-related boundary.

The next issue to watch will be how affected associations interpret that boundary when preparing their annual compliance records. Further clarification could determine whether the procedure becomes a straightforward filing exemption or a case-by-case exercise for football’s national governing bodies.