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Bloomberg: IRS, Canada Agree on World Cup Participants’ Income Allocation

Michael Rapoport (Bloomberg): IRS, Canada Agree on World Cup Participants’ Income Allocation:

Participants of the 2026 FIFA World Cup can use a proportional formula to allocate the prize money and other compensation they receive among the countries hosting the tournament, the IRS said Wednesday.

The IRS and the Canada Revenue Agency have agreed on a “reasonable” allocation method based on the number of matches played in each of the three World Cup host countries—the US, Canada, and Mexico—relative to the total number of matches the team plays, the IRS said in an emailed statement.

National teams and players can determine the allocation by multiplying the relevant earnings by the number of matches in each country and dividing the result by the total number of matches played across all three countries. The same method can apply to independent contractors engaged by the teams; nonplayer employees of the teams can use a time-based allocation factor, the IRS said.

However, taxpayers can choose an alternative method of income allocation if their specific facts and circumstances justify it and if it more accurately reflects their situation, the IRS said. Taxpayers are encouraged to apply their allocation method consistently in their country of residence and across all three host countries.


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