The 2026 FIFA World Cup will be the largest edition in tournament history. FIFA says it will feature 104 matches across 16 host cities, with 78 matches in the United States. The Taxpayer Advocate Service, in its June 2026 tax tip, notes that the event will be jointly hosted by the United States, Canada, and Mexico, with most matches taking place in the United States. For foreign participants, that geography creates a tax issue long before the first whistle blows.
If you are a nonresident alien traveling to the United States for World Cup-related work, you may owe U.S. federal tax on income connected to services performed in the country. That can apply even when your stay is brief. Furthermore, the rules can affect not only athletes, but also coaches, performers, team staff, media professionals, and service businesses supporting the event.
Who this guide is for
This guide is for foreign participants who will earn money in connection with World Cup activities in the United States. That includes athletes, performers, coaches, team personnel, media professionals, and businesses providing event-related services. The key point is simple: temporary travel does not erase U.S. tax exposure when the income arises from work performed in the United States.
The IRS and TAS both frame the issue broadly. They treat U.S.-source income from services performed in the United States as potentially taxable for nonresident aliens and foreign entities. Consequently, participants should plan early, especially if their compensation will come from appearances, match participation, endorsements, broadcasts, or other event-linked services performed on U.S. soil.
The core tax rule: U.S.-source income and withholding
The basic rule is straightforward, but the mechanics are not. The TAS tax tip says nonresident alien individuals and foreign entities are generally subject to U.S. federal income tax and reporting rules on U.S.-source income connected to services performed in the United States. For nonemployees, that compensation is generally reported on Form 1042-S and subject to 30% federal withholding on the gross amount unless a lower treaty rate, statutory exemption, or Central Withholding Agreement applies.
That “gross amount” point matters. Withholding often occurs before any deductions for expenses. Therefore, a participant can face a cash-flow problem even when the final tax bill later turns out to be lower. Furthermore, the payment source—not the recipient—usually bears the compliance burden at the front end. Teams, leagues, promoters, and event organizers typically collect documentation, withhold the tax, and remit it to the IRS.
The reporting side matters just as much. The IRS says Form 1042 is the annual withholding tax return for U.S.-source income of foreign persons. It also says Form 1042-S reports the income, tax withheld, and tax deposited, and it can be required even when no tax is withheld because a treaty or exemption applies. In other words, a participant may still receive a tax statement even if the payment was fully or partially exempt from withholding.
If you are an employee, the rules change
The TAS tax tip also draws a clear line between independent contractors and employees. If the participant is treated as an employee, wages for services performed in the United States are generally subject to U.S. wage withholding rules using graduated rates. Consequently, classification matters from day one. A contractor setup and an employment setup can lead to very different withholding and reporting outcomes.
Which U.S. return may be required
Withholding does not always end the story. Even if tax is withheld from a payment, the participant may still need to file a U.S. tax return. Filing helps reconcile withholding with the actual tax liability, report income correctly, and claim deductions or treaty benefits when allowed. It also allows a participant to recover any overwithholding.
For nonresident alien individuals, the usual return is Form 1040-NR. The IRS says nonresident aliens who are required to file an income tax return must use Form 1040-NR, and it also notes that the form applies when the person has income subject to tax or wants to claim a refund of excess withholding. Foreign corporations, by contrast, generally file Form 1120-F.
That distinction is critical for foreign teams, service companies, and broadcast entities. A corporation does not file the same form an individual athlete files. Furthermore, a business that performs U.S.-connected services may need to report income, deductions, credits, and liability on the foreign corporation return rather than on an individual return.
How to claim treaty benefits before money is paid
Tax treaties can reduce or eliminate U.S. tax or withholding, depending on the country and the income type. However, treaty relief is not automatic. The TAS tip says participants generally must provide documentation to the withholding agent before payment is made. That paperwork tells the payer whether withholding should apply at a reduced rate or not at all.
For personal services income, the IRS says Form 8233 is the correct vehicle for a nonresident alien individual claiming a treaty exemption on compensation for independent or certain dependent personal services. The instructions also emphasize that the user must understand the treaty terms before completing the form. That is not a small detail. Treaty claims fail most often when the claimant assumes the treaty applies without checking the specific article and conditions.
For other income types, the form changes. The IRS says Form W-8BEN is used by individuals to establish foreign status and, when applicable, claim a reduced rate or exemption for certain treaty-covered income. The IRS also says nonresident alien individuals claiming exemption from withholding on compensation for personal services performed in the United States should not use Form W-8BEN for that purpose. Foreign entities generally use Form W-8BEN-E instead.
A taxpayer identification number usually comes into play as well. The TAS tip says claimants will usually need a Social Security number, Individual Taxpayer Identification Number, or Employer Identification Number, depending on the case. Therefore, this is one more reason to organize the paperwork before the first U.S. payment goes out.
Why a Central Withholding Agreement may be the cleanest solution for artists and athletes
Foreign artists and athletes have a special option: the Central Withholding Agreement, or CWA. The IRS says the program helps foreign artists and athletes understand their federal tax responsibilities, meet filing and payment obligations, and request a lower withholding rate. The TAS tax tip likewise notes that a CWA can base withholding on estimated net income rather than 30% withholding on gross income.
That difference can be substantial. Gross withholding can overstate the cash needed to satisfy the tax system when the participant has travel, lodging, production, agent, or related expenses. A CWA can make withholding more accurate, because the IRS uses estimated net income rather than gross receipts. Furthermore, the IRS says the withholding agent remains responsible for withholding and depositing taxes unless a CWA is in effect.
Timing is crucial. The IRS says Form 13930 must be submitted no later than 45 days before the first itinerary event in the United States, and late applications are not processed. If the application is timely, the IRS reviews it, may request more information, and, if approved, requires the taxpayer and withholding agent to sign the agreement. Even then, the participant must still file a U.S. tax return after the activity ends.
State tax rules can create a second layer of exposure
Federal tax is only part of the picture. The TAS tip warns that each U.S. state where World Cup events or related services take place may impose its own tax rules. Those rules can include income tax or withholding, and they vary by state. Consequently, a participant working in more than one U.S. location may have multiple state-level obligations, not just one federal filing.
This is where planning pays off. If you know the itinerary in advance, you can map the states, identify the withholding agents, and determine which filings may be necessary after the event. That planning step is especially important for touring personnel, media crews, and service businesses moving from city to city.
A practical pre-trip checklist
Before traveling, the safest move is to prepare in the same way a team prepares for a knockout bracket. First, decide whether the payment will be treated as employee wages or independent contractor income. Second, obtain the right taxpayer identification number. Third, deliver the correct foreign-status or treaty documentation to the withholding agent. Fourth, keep clean records of U.S.-related income and expenses. Fifth, decide whether a CWA makes sense for artists or athletes.
That checklist is not bureaucratic clutter. It is risk control. Proper documentation can reduce withholding errors, prevent delayed refunds, and limit disputes after the event. Furthermore, it can save a participant from discovering, too late, that a treaty benefit was available but never claimed.
Where to get help
The tax rules for nonresident aliens are highly technical, and World Cup participants are often dealing with short timelines and multiple payers. The TAS tip recommends consulting a tax professional familiar with nonresident tax rules. It also points participants to IRS and TAS resources for additional guidance.
That advice is sound. A single missed form, a late treaty claim, or an incorrectly classified payment can change the withholding result materially. Therefore, foreign participants should treat U.S. tax preparation as part of event planning, not as an afterthought once the trip is over.
Final takeaway
The 2026 FIFA World Cup will be a global sporting event, but U.S. tax rules will still apply to many participants who work on U.S. soil. If you earn income from World Cup-related services in the United States, you may need treaty documentation, withholding forms, a CWA, and a U.S. tax return. Planning early is the difference between orderly compliance and expensive confusion.
