Foreign Nationals and American Taxes: The 2026 FIFA World Cup

The United States will host 78 of the 104 matches at the 2026 FIFA World Cup, featuring teams from up to 48 nations across 11 U.S. cities. Traveling with these national teams will be countless athletes, artists, and staff. 

Those seeking to understand the tax responsibilities for foreign nationals traveling with the World Cup should examine these real-life potential tax situations faced by the World Cup’s star players and coaches. (Note that although the people discussed herein are real, their tax situations are imagined for the sake of narrative.) 

Tax Withholdings and Double Taxation Agreements 

Carlo Ancelotti, who became the winningest coach in European club football after a storied playing career, will travel to the 2026 FIFA World Cup as the head coach of the Brazilian national team. Generally, the United States requires that employers, organizers, or other payors withhold a flat 30% of a payee’s U.S.-sourced income. This means that 30% of Ancelotti’s salary, appearance fees, performance bonuses, and all other compensation related to games played in the U.S. by the Brazilian national team must be withheld and remitted to the IRS. 

Ancelotti’s job with the Brazilian national team requires him to be in Brazil only a few months each year. It is likely that he retained tax residency in his native Italy. This is relevant because Italy and the United States have a double taxation agreement (DTA).  

As an employee of the Brazilian national team, Ancelotti provides dependent personal services. Per Article 15 of the DTA between Italy and the United States, Ancelotti’s U.S.-sourced dependent personal services are exempt from withholdings.  

Brazil, however, has no DTA with the United States. If Ancelotti did, in fact, convert his tax residency to Brazil upon accepting the job with the national team, 30% of his earnings would be withheld unless he applies for a central withholding agreement (CWA). 

Central Withholding Agreements 

After leading the 2018 French national team to their second World Cup trophy and then narrowly losing to Lionel Messi’s Argentina in the 2022 World Cup final, superstar striker Kylian Mbappé will travel to North America to try to guide the French national team to their third World Cup title this year. When he is not playing for the French national team, Mbappé plays for the Spanish club team Real Madrid and is therefore likely a Spanish tax resident.  

Unlike Ancelotti, who is an employee of the Brazilian national team, Mbappé is employed by Real Madrid and likely acts as a contractor for the French national team. This would mean he provides his national team with independent personal services. Article 15 of the DTA between Spain and the United States exempts independent personal services from taxation.  

Unfortunately for Mbappé, Article 19 of the Spanish-American DTA specifically removes athletes and artists from this exemption. Mbappé will therefore be subject to U.S. withholdings for the portion of his compensation related to games played in the United States this summer. Withholdings will be calculated on gross compensation, including significant reimbursements.  

France will play their first game of the World Cup on June 16 against Senegal at MetLife Stadium in East Rutherford, New Jersey. Imagine that Kylian Mbappé will be paid a $90,000 appearance fee, and reimbursed $10,000 for travel and accommodation. Mbappé, who is a business unto himself, will not keep that full amount. His agent and manager will each expect 10% of his appearance fee, and he will pay his athletic trainer $2,000 for pre- and post-match treatment. This means that Mbappé nets $70,000 of the $100,000 paid to him. The IRS, however, will expect 30% of the full $100,000. This $30,000 withheld effectively constitutes a tax rate of 42%, which is 12% higher than the mandated 30%. 

When Mbappé’s U.S. tax team files his 2026 nonresident tax return (form 1040-NR), they will deduct expenses related to his U.S.-sourced income and recoup excess withholding. This will not happen until early 2027. Until he receives a refund for excess withholding, Mbappé will have effectively loaned the U.S. government tens of thousands of dollars at 0% interest.  

With some foresight, however, Mbappé’s tax team could mitigate this situation by applying for a CWA. By providing the IRS with information (e.g., a spreadsheet of all foreseen expenses, a list of signed agreements related to U.S.-sourced income), the IRS and Mbappé can agree to a withholding rate closer to 30% of his expected net. 

Tax Filings and Other Considerations 

World Cup host states California and New Jersey have notoriously aggressive “jock taxes” that do not conform to federal DTAs. Beyond state complexity, Mbappé and Ancelotti will need to file Form W-8BEN with their respective payors before they are paid. If they decide to apply for CWAs, they will need to submit Form 13930 along with the requisite backup files. In 2027, they will need to file a nonresident tax form 1040-NR, plus state returns.   

Foreign nationals seeking advice on navigating the complexities of U.S.-sourced income should reach out to Evolved Tax or another qualified U.S. tax professional for a consultation.