rp-26-28.pdf

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Part III

Administrative, Procedural, and Miscellaneous

26 CFR 1.6033-2: Returns by exempt organizations and returns by certain nonexempt
organizations.

Rev. Proc. 2026-28

SECTION 1. PURPOSE
This revenue procedure exercises the discretionary authority under § 6033(a)(3)(B)
of the Internal Revenue Code (Code)
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to relieve certain Fédération Internationale de
Football Association (FIFA) member associations whose national teams are competing
in the FIFA World Cup 2026 (participating member associations or PMAs) from the
requirement of having to file an annual information return on Form 990, Return of
Organization Exempt From Income Tax. As described in section 3 of this revenue
procedure, this exception applies to any foreign PMA competing in the FIFA World Cup

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Unless otherwise specified, all “section” or “§” references are to sections of the Code or the Internal
Revenue Regulations (CFR Title 26).

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2026 exempt from federal income tax under § 501(a) (other than a private foundation or
a § 509(a)(3) supporting organization) for any taxable year in which the PMA 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. References in this revenue
procedure to Form 990 include Form 990-EZ, Short Form Return of Organization
Exempt from Income Tax. Rev. Proc. 2011-15, 2011-3 I.R.B. 322, is amplified.
SECTION 2. BACKGROUND
.01 Section 6033(a)(1) generally requires exempt organizations 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.
.02 Section 6033(a)(3)(B) provides that the Secretary of the Treasury or the
Secretary’s delegate (Secretary) may relieve exempt organizations from the annual
filing requirement if the Secretary determines that such filings are not necessary to the
efficient administration of the internal revenue laws. Section 1.6033-2(g)(6) delegates
such discretionary authority to the Commissioner. See § 1.6033-2(g)(1) for a partial list
of organizations that are not required to file annual information returns.
.03 The Pension Protection Act of 2006, Public Law 109-280 (120 Stat. 780),
amended § 6033(a)(3)(B) to remove the Secretary's authority to relieve organizations
described in § 509(a)(3) (supporting organizations) from filing an annual information
return.
.04 Rev. Proc. 2011-15, 2011-3 I.R.B. 322, relieves from the Form 990 filing

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requirement foreign organizations (other than private foundations) whose annual gross
receipts are normally not more than $50,000 from sources within the United States and
that have no significant activity in the United States.
.05 Section 53.4948-1(b) provides that gifts, grants, contributions or membership
fees received directly or indirectly by a foreign organization from a United States
person, as defined in § 7701(a)(30), are from sources within the United States. For
purposes of this revenue procedure, the source of an organization's gross income from
gifts, grants, contributions or membership fees is determined by applying § 53.4948-
1(b). See § 1.6033-2(k)(3).
.06 For purposes of this revenue procedure, the source of an organization's gross
income other than gifts, grants, contributions, and membership fees is determined by
applying the rules in §§ 861 through 865 and the regulations thereunder. See § 1.6033-
2(k)(3).
.07 For purposes of this revenue procedure, a foreign organization is any
organization not described in § 170(c)(2)(A). See § 1.6033-2(k)(1).
.08 Section 7701(a)(9) defines “United States” when used in a geographical sense
as only the States and the District of Columbia.
.09 Section 7701(a)(30) defines “United States person” as a citizen or resident of the
United States, a domestic partnership, a domestic corporation, any estate that is not a
foreign estate (within the meaning of § 7701(a)(31)), or any trust if “(i) a court within the
United States is able to exercise primary supervision over the administration of the trust,
and (ii) one or more United States persons have the authority to control all substantial

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decisions of the trust.”
.10 Section 6033(i) provides that any organization relieved from filing an annual
return pursuant to § 6033(a)(3)(B) by reason of its gross receipts must furnish annually,
in electronic form, a notice containing the information described in § 6033(i)(1). The
annual notice requirement is satisfied by submitting a Form 990-N e-Postcard. See
§ 1.6033-6.
.11 The Secretary has determined that the filing of Form 990 by any foreign PMA
competing in the FIFA World Cup 2026 under the circumstances described in section 3
of this revenue procedure is not necessary to the efficient administration of the internal
revenue laws for the following reasons:
(1) Such PMAs are not expected to have recurring 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 (including incidental
administrative and financial arrangements necessary or appropriate to facilitate their
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
disproportionate 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

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in nature in those taxable years in which the PMA is exempted from filing.
SECTION 3. SCOPE
This revenue procedure applies to any foreign PMA competing in the FIFA World
Cup 2026 exempt from federal income tax under § 501(a) (other than a private
foundation or a § 509(a)(3) supporting organization), for any taxable 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 § 501(a).
SECTION 4. PROCEDURE
.01 A foreign PMA competing in the FIFA World Cup 2026 exempt from federal
income tax under §501(a) (other than a private foundation or a § 509(a)(3) supporting
organization) and otherwise required to file Form 990 will be relieved from the
requirement to file Form 990 for any taxable year in which the organization does not
have any 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 (such as prize
money from FIFA and promotional income from third persons related to the foreign
PMA’s participation in the FIFA World Cup 2026).
.02 A foreign PMA that is not required to file Form 990 for a taxable year by virtue of
section 4.01 of this revenue procedure is also not subject to the requirement under

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§ 6033(i) to submit a Form 990-N e-Postcard for such taxable year. Section 6033(i)
does not apply to such an organization because the exception from filing Form 990 in
section 4.01 of this revenue procedure is based on the organization’s gross income
rather than its gross receipts.
.03 If for any taxable year such an organization does not satisfy the conditions
described in section 4.01 of this revenue procedure, the organization is required to file
the annual information return or submit the annual notice for such taxable year (unless
another filing exception applies).
SECTION 5. EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2011-15 is amplified.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective on July 24, 2026 and applies to taxable years
beginning on or after January 1, 2025.
SECTION 7. DRAFTING INFORMATION
The principal author of this revenue procedure is Seth Groman of the Office of
Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment
Taxes). For further information regarding this revenue procedure contact Seth Groman
on (202) 317-5640 (not a toll free call).