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§ 1373. Foreign income
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(a) |
S corporation treated as partnership, etc. |
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For purposes of subparts A and F of part III, and part V, of subchapter N (relating to income from sources without the United States) - |
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(1) |
an S corporation shall be treated as a partnership, and |
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(2) |
the shareholders of such corporation shall be treated as partners of such partnership. |
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(b) |
Recapture of overall foreign loss |
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For purposes of section 904(f) (relating to recapture of overall foreign loss), the making or termination of an election to be treated as an S corporation shall be treated as a disposition of the business. |
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