Bulletin No. 2026–33

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2026–33

August 10, 2026

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

EXEMPT ORGANIZATIONS

Rev. Proc. 2026-28, page 175.

This revenue procedure amplifies Rev. Proc. 2011-15, 2011-3

I.R.B. 322 by relieving tax-exempt foreign participating member associations (PMAs) of the Fédération Internationale de

Finding Lists begin on page ii.

Football Association (FIFA) that are competing in the 2026

FIFA World Cup from the requirement of having to file a Form

990-series annual information return or notice for tax years

in which they have no gross income from sources within the

United States or effectively connected with the conduct of a

trade or business within the United States other than income

related to participation in the 2026 FIFA World Cup.

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and

enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

of the tax laws, including all rulings that supersede, revoke,

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

relied on, used, or cited as precedents by Service personnel in

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

August 10, 2026 

Bulletin No. 2026–33

Part III

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)1 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 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 deter-

1

mines 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

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 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 in nature in

those taxable years in which the PMA is

exempted from filing.

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

Bulletin No. 2026–33

175

August 10, 2026

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

August 10, 2026

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 § 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

176

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).

Bulletin No. 2026–33

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

­effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus,

if an earlier ruling held that a principle

applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously

published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations

to show that the previous published rulings will not be applied pending some

future action such as the issuance of new

or amended regulations, the outcome of

cases in litigation, or the outcome of a

Service study.

Abbreviations

The following abbreviations in current

use and formerly used will appear in

material published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2026–33

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

i

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

August 10, 2026

Numerical Finding List1

Bulletin 2026–33

Announcements:

2026-11, 2026-29 I.R.B. 49

2026-12, 2026-29 I.R.B. 50

2026-13, 2026-32 I.R.B. 173

Notices:

2026-39, 2026-27 I.R.B. 1

2026-38, 2026-28 I.R.B. 30

2026-40, 2026-28 I.R.B. 33

2026-41, 2026-29 I.R.B. 39

2026-42, 2026-29 I.R.B. 41

2026-43, 2026-29 I.R.B. 42

2026-21, 2026-30 I.R.B. 51

2026-44, 2026-32 I.R.B. 143

Revenue Procedures:

2026-25, 2026-29 I.R.B. 45

2026-18, 2026-30 I.R.B. 53

2026-26, 2026-31 I.R.B. 131

2026-32, 2026-32 I.R.B. 146

2026-28, 2026-33 I.R.B. 175

Revenue Rulings:

2026-12, 2026-28 I.R.B. 27

2026-13, 2026-32 I.R.B. 132

Treasury Decisions:

10051, 2026-31 I.R.B. 118

10052, 2026-31 I.R.B. 121

10050, 2026-32 I.R.B. 134

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2026–27 through 2026–52 is in Internal Revenue Bulletin

2025–52, dated December 21, 2025.

1

August 10, 2026

ii

Bulletin No. 2026–33

Finding List of Current Actions on

Previously Published Items1

Bulletin 2026–33

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2026–27 through 2026–52 is in Internal Revenue Bulletin

2025–52, dated December 21, 2025.

1

Bulletin No. 2026–33

iii

August 10, 2026

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue

Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,

we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page

www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.

NW, IR-6230 Washington, DC 20224.