First major financial development this morning: The IRS has just exempted foreign FIFA associations from Form 990 filing for the 2026 World Cup, but UK entities still face full HMRC compliance. Meanwhile, a new Senate bill proposes changes to FBAR and Form 8938 that could affect UK expats and investors. Here’s what you need to know to secure your tax compliance certificate and avoid penalties.
If you are a UK taxpayer or business with international ties, staying on top of both HMRC and IRS rules is critical. The tax compliance certificate is your proof of good standing with HMRCтАФwithout it, you may face delays in foreign tax credits or cross-border transactions. We break down the latest updates and a step-by-step guide to getting yours fast.
Today’s Morning Impact Analysis (Top Market Hooks)
- IRS Ruling: FIFA associations exempted from Form 990тАФbut UK entities still must report to HMRC.
- Senate Bill: Proposed FBAR simplification and math error response extension from 60 to 120 daysтАФtarget UK expats.
- UK Certificate: HMRC digital process for tax compliance certificate now takes 15 working daysтАФbut can stretch to 4-6 weeks.
- Charity Disclosure: HR 9772 would require UK charities receiving US donations to disclose foreign contributionsтАФmonitor closely.
- Leadership Changes: New Treasury and IRS nominees may affect international tax cooperationтАФPillar 2 implications.
Breaking: IRS Exempts FIFA Associations from Form 990 тАУ What It Means for UK Entities
On July 24, the IRS issued IRS Rev. Proc. 2026-28, exercising its authority under Section 6033(a)(3)(B) to relieve foreign FIFA Participating Member Associations (PMAs) from filing Form 990 or Form 990-EZ for any taxable year where the PMA has no U.S. source income except World CupтАУrelated revenue. This is a targeted relief for associations whose U.S. presence is limited to tournament activities.
Impact on UK entities: While this is good news for UK football associations with US revenue, they must still comply with HMRC reporting. HMRC does not offer a similar blanket exemption. UK associations must file annual returns and may need a tax compliance certificate uk to prove good standing for withholding tax claims or double taxation relief.
| Aspect | Before Rev. Proc. 2026-28 | After Rev. Proc. 2026-28 |
|---|---|---|
| Form 990 requirement | Required if gross receipts > $200k and assets > $500k | Exempt for FIFA PMAs meeting criteria |
| Scope of relief | No exemption | Only for PMAs with no US income except World Cup related |
| Eligible countries | All | Only those whose PMAs competed in 2026 World Cup |
| UK impact | Full compliance with HMRC | US filing burden reduced, but UK obligations unchanged |
Bitter truth: Even if you qualify for this US exemption, your UK compliance workload stays the same. Many associations will still file annual returns with HMRC and may need a certificate of residence or tax compliance certificate for cross-border tax relief.
New US Bill: FBAR & Form 8938 Changes тАУ How UK Expats and Investors Are Affected
A recently drafted Senate tax administration bill, covered by Accounting Today, includes Title II: American Citizens Abroad. Key proposals are an FBAR and Code simplification study, a GAO burden study, and a math error response extension from 60 to 120 days for overseas taxpayers. This could significantly reduce accidental penalties for UK expats who miss FBAR deadlines.
But here is the risk: UK CRS reporting already captures most foreign accounts, yet FBAR requires a separate filing. This duplication is a common trap leading to $10,000 penalties per violation. If you have both UK and US accounts, you must track both HMRC and IRS deadlines. This is where most people make their biggest mistakeтАФthey assume CRS compliance satisfies FBAR, but it does not.
| Requirement | FBAR (FinCEN Form 114) | Form 8938 | HMRC Foreign Account Reporting |
|---|---|---|---|
| Threshold | Foreign accounts > $10k aggregate | Varies by filing status (e.g., $50k for married filing jointly) | Any foreign account with taxable income |
| Deadline | April 15, extended to October 15 | With tax return (April 15) | Self-assessment deadline (January 31 after year-end) |
| Penalty | Up to $10k per willful violation | $10k per missed form | Up to ┬г300 per failure |
| Reporting overlap | Same accounts but different forms | Same as FBAR but higher threshold | UK CRS covers automatic exchange |
Bitter truth: This bill is only proposedтАФdo not wait for it. Current FBAR and Form 8938 rules remain in force, and ignorance is no defence. Use a dual-qualified advisor to avoid duplication penalties.
How to Get a Tax Compliance Certificate Online: HMRCтАЩs Digital Process (2026 Update)
A tax compliance certificate from HMRC is your official proof that your UK tax affairs are up to date. It is often required when claiming foreign tax credits, selling a business, or dealing with overseas tax authorities. Note the difference: a certificate of residence (form UK-APP) proves you are a UK resident, while a tax compliance certificate specifically confirms compliance. Here is the step-by-step process to get yours online.
- Register for HMRC online services via Government Gateway. If you have multiple tax accounts, ensure all are linked.
- File your tax returns for the last 4 years. If any returns are overdue or missing, your application will be automatically rejected.
- Check your tax account for any unpaid amountsтАФoutstanding tax blocks the certificate.
- Request the certificate online through the HMRC service. Choose the correct type (personal or company).
- Wait for processing: HMRC states 15 working days, but real-world experiences suggest 4-6 weeks if they need to verify residence history or if returns are complex.
Bitter truth: If you have any outstanding returns or unpaid taxes, your application will be automatically rejected. You cannot get a certificate until HMRC considers you fully compliant. Also, online applications are fasterтАФpostal applications take 4 to 6 weeks longer, and HMRC does not expedite either method.
Implications for UK Charities Receiving US Donations: New Reporting Rules Ahead
Proposed bill HR 9772 would require US nonprofits to disclose aggregate contributions from foreign nationals of countries of concern. For UK charities with US donors, this means if your charity has gross receipts over $200k (approx ┬г160k) or assets over $500k (approx ┬г400k), you may need to report receipts from China, Russia, North Korea, and Iran. Non-compliance could jeopardise your US tax-exempt status.
| Country of Concern | Sample Disclosure Requirement |
|---|---|
| China | Aggregate contributions from Chinese foreign nationals |
| Russia | Aggregate contributions from Russian foreign nationals |
| North Korea | Aggregate contributions from North Korean foreign nationals |
| Iran | Aggregate contributions from Iranian foreign nationals |
HR 9772 foreign donation disclosure is not yet law, but similar trends are emerging from the OECD. Start updating your donor intake forms now to capture nationality and avoid scrambling later.
Senate Confirmation Progress: New Treasury and IRS Leaders тАУ What It Means for International Tax Cooperation
The Senate Finance Committee has advanced four nominations: Francis Brooke (Deputy Treasury), Erin Browne (Under Secretary for International Affairs), Sriprakash Kothari (Assistant Secretary for Economic Affairs), and George McMaster (Assistant Secretary for Financial Markets). The Senate Finance Committee markup indicates they will likely be voted on before August recess. However, IRS Chief Counsel nominee Jim Gadwood has no hearing yet, delaying critical guidance on international matters.
What this means for UK readers: New US leadership could speed up or derail tax treaty updates, especially for Pillar 2 implementation. For UK multinationals, the pace of mutual agreement procedures and exchange of information agreements may be affected. No immediate action needed, but monitor developments closely.
| Nominee | Position | Status | International Tax Role |
|---|---|---|---|
| Francis Brooke | Deputy Treasury | Advanced, pending full Senate vote | Oversees all Treasury tax policy |
| Erin Browne | Under Secretary for International Affairs | Advanced, pending full Senate vote | Directly manages international tax treaties |
| Sriprakash Kothari | Assistant Secretary for Economic Affairs | Advanced, pending full Senate vote | Economic analysis of tax policy |
| George McMaster | Assistant Secretary for Financial Markets | Advanced, pending full Senate vote | Financial market regulation |
| Jim Gadwood | IRS Chief Counsel | No hearing yet | Legal guidance on IRS rules |
Bitter truth: The delay in GadwoodтАЩs hearing means critical guidance on digital asset reporting and cross-border information exchange may be stalled for months. Expect ambiguity until the new leadership is fully in place.
Tax Compliance Certificate Template & Checklist for UK Businesses (Free Download Coming)
HMRC does not provide an official template for a tax compliance certificateтАФthey issue a specific form after you apply. However, you can use a checklist to assemble your documents before applying, which saves time and avoids rejections. Here are the five essential items:
- SA302s for the last 4 tax years тАУ ensure they match HMRCтАЩs records exactly.
- Proof of residence (e.g., council tax bill, utility bill dated within 3 months).
- Business registration (if applying as a company тАУ e.g., CT603).
- CRS status report (if applicable) тАУ to avoid duplicate reporting.
- Payment confirmation for any outstanding taxes тАУ all balances must be cleared.
Decision point: If you need the certificate urgently, use the online service. Postal applications take 4 to 6 weeks longer. For OECD global minimum tax (Pillar 2) compliance, consider professional advice to ensure your certificate covers the right jurisdictions.
Bitter truth: Even with a perfect list, HMRC may reject your application if your SA302 doesn’t match their system records. Double-check your tax account before applying.
Tax Compliance Certificate UK: Common Questions Answered (2026)
FAQs: Frequently Asked Questions
Q: What is a tax compliance certificate and when do UK residents need it?
Q: How to get a tax compliance certificate online from HMRC quickly?
Q: What documents are required for a tax compliance certificate template?
Q: Do UK companies need a separate certificate?
Q: What is the difference between a UK tax compliance certificate and a certificate of residence?
This article provides general financial information and is not tax or legal advice. International tax rules are complex and subject to change. Always consult a qualified tax professional familiar with your specific circumstances. Readers in the UK should verify current HMRC procedures and consider cross-border implications with a dual-qualified advisor. The information here is as of July 2026 and may be superseded.
