Issue Number: 2026-03 General Tax Resources for the 2026 FIFA World Cup The 2026 FIFA World Cup will be jointly hosted by the United States, Canada and Mexico. A total of 104 matches will be played from June 11 to July 19, 2026, featuring 48 national teams. The United States will host 78 matches across eleven cities including the final match.
Nonresident individuals and foreign entities participating in this event may have tax obligations in the United States. The resources listed below can assist World Cup participants gain a better understanding of their tax responsibilities in the United States.
Note that the following information is not an exhaustive list of all federal tax laws that may apply or all possible federal tax considerations. Additionally, the resources listed below do not address state or local taxes.
General Rules
Tax Reporting Requirements
Foreign individuals and entities are generally subject to tax on their U.S. source income or earnings connected with activities performed in the United States. Generally, non-employee compensation, including earnings from independent personal services (e.g., as a contractor or performer), is subject to 30% federal withholding tax on the gross amount of U.S. source payments. Withholding agents (typically the promoter, league, team or event organizer) must withhold this tax and remit it to the IRS. In addition, withholding agents are required to report the payments and the tax withheld on Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons, and Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding. The foreign individuals and entities performing the services will also have their own filing requirements in the United States, generally Form 1040-NR, U.S. Nonresident Alien Income Tax Return, if a foreign individual or Form 1120-F, U.S. Income Tax Return of a Foreign Corporation, if a foreign corporation.
If the foreign person is an employee, separate payroll withholding rules apply based on graduated rates under U.S. wage withholding rules.
Treaty Guidance
Foreign individuals and entities may claim a reduced withholding rate or exemption under an applicable treaty between the United States and their home country. To claim treaty benefits, individuals performing personal services will generally provide Form 8233, Exemption From Withholding on Compensation for Independent (and Certain Dependent) Personal Services of a Nonresident Alien Individual, to the withholding agent as documentation. Individuals with other types of income will generally provide Form W-8BEN, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding and Reporting (Individuals), and entities will generally provide Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities). A foreign individual is generally required to have either a Social Security Number (SSN) or an Individual Tax Identification Number (ITIN) to claim treaty benefits; a foreign entity is generally required to have an Employer Identification Number (EIN) to claim treaty benefits. A foreign person claiming treaty benefits is also generally required to be a resident of the treaty country, the income must qualify under specific treaty provisions, and meet other applicable requirements under the treaty. Note: Individuals present in the U.S. under a work visa, such as O-1, P-1, etc., are generally not eligible for an ITIN and must apply for an SSN. If the Social Security Administration determines that a foreign person is not eligible for an SSN, a denial letter from the Social Security Administration must be obtained and attached to the Form W-7, Application for IRS Individual Taxpayer Identification Number. Individuals - General Requirements
- Obtaining an ITIN or SSN
- Claiming Tax Treaty Benefits
- Required U.S. Tax Filings
A nonresident alien individual generally must file IRS Form 1040-NR to: - Report U.S. source income,
- Reconcile tax liability with amounts withheld,
- Claim deductions to the extent allowed, and
- Claim treaty benefits not fully realized through withholding.
- See:
International Businesses - General Requirements
- Withholding Tax
- Documentation
- Tax Treaties
- Required U.S. Tax Filings
A foreign corporation or other entity engaged in a U.S. trade or business, such as income from a sports event or contractual services, generally must file Form 1120-F to: - Report effectively connected income,
- Determine taxable income, and
- Pay U.S. tax after allowable deductions
- See:
- Wages vs. Independent Services
Foreign Artists and Athletes The IRS has a Central Withholding Agreement ("CWA") program that allows individual nonresident alien artists and athletes, who are performing independent personal services and participate in a specific tour or series of athletic events in the United States, to enter into advance agreements with the IRS and a designated withholding agent to determine how much tax will be withheld from their income. Under a CWA, the artist or athlete is required to file a final income tax return to compute the appropriate amount of income tax at graduated tax rates and pay any tax due after considering the tax withheld. Artists and athletes who are performing dependent personal services are not eligible for a CWA.
To request a CWA, the artist or athlete must submit a complete Form 13930, Application for Central Withholding Agreement (CWA). An application for a CWA must be submitted at least 45 days before the first event date listed on the application to allow for a timely evaluation. An application received by the IRS less than 45 days before the first event listed in the application, or that is not properly completed, will be rejected and returned to the applicant. State Tax Considerations
In addition to federal tax rules, each U.S. state where the events occur may impose its own state income or withholding tax on earnings from activities conducted within that state. Rules vary by state. For additional information see State government websites that may contain useful information concerning state tax requirements. Back to top
Thank you for subscribing to e-News for Withholding Agents, an IRS email service. If you know someone who might want to subscribe to this mailing list, please forward this message to them so they can subscribe. This message was distributed automatically. Please Do Not Reply To This Message. |
No comments:
Post a Comment