The 2026 FIFA World Cup will undoubtedly be a monumental event across North America. Hosted jointly by the United States, Canada, and Mexico, this expanded 48-team tournament will draw global talent, corporate sponsors, and millions of fans.

However, behind the global spectacle lies a highly intricate web of cross-border tax and valuation challenges. At Sullivan & Company CPA Inc., we routinely help high-net-worth individuals and their advisors navigate complex financial terrain, and global tournaments represent the pinnacle of international tax complexity.

The Cross-Border Wealth Puzzle

Elite athletes often live, train, and compete in entirely different tax jurisdictions. When a player represents a national squad while remaining under contract with a foreign club, overlapping tax obligations emerge. For example, a scenario highlighted by Bloomberg tax analysts describes a player holding citizenship in one nation, playing professionally in another, training in a third, and competing in the U.S. Multiple jurisdictions may claim taxing rights on the same revenue stream.

Source Taxation and Entity Structuring

A primary hurdle is source taxation—the rule that income is taxable where it is earned. For participants in U.S. matches, the IRS may tax match earnings, appearance fees, and tournament-related endorsements. U.S. tax treaties typically permit the taxation of athlete income exceeding $20,000 tied to domestic performances.

Classification further complicates matters. Depending on the jurisdiction, coaches or staff might be treated as employees or independent contractors. Slight variations in classification drastically alter withholding obligations and payroll exposure, emphasizing the need for proactive entity structuring and precise contract analysis.

Valuation of Sponsorships and Intellectual Property

Many participants generate more wealth from endorsements than match play. Proper tax treatment relies heavily on distinguishing between performance-based income and intellectual property licensing. In our valuation and forensic practice, we see firsthand how the misclassification of mixed income streams can trigger intense tax controversies. Properly valuing these endorsements is critical for defensible reporting.

Strategic Planning Reduces Controversy

The tax risks associated with the World Cup extend beyond the players to include media teams, sponsors, and hospitality providers. For high-net-worth families, international business owners, or fiduciaries dealing with cross-border assets, the underlying lesson is universal: robust planning and clear valuation strategies are essential to avoid future litigation.

If you need clarity on complex estate, forensic accounting, or valuation disputes, our Burlingame team is ready to deliver defensible results. Contact Sullivan & Company CPA Inc. today to discuss your comprehensive wealth preservation strategy.