26 U.S.C. § 1373 — Foreign income
submitted 44 years ago by Pub. L. 97-354 to r/title-26-INTERNAL-REVENUE-CODE · 98 words · no verdicts yet
For specified foreign-income rules, an S corporation is treated as a partnership and its shareholders as partners. Making or ending an S-election is treated as disposing of the business for overall foreign-loss recapture.
(a) S corporation* treated as partnership*. For subparts A and F of part III and part V of subchapter N, concerning income from outside the United States: (1) treat an S corporation* as a partnership; and (2) treat its shareholders* as partners. (b) Recapture of overall foreign loss. For section 904(f), making or ending an election to be an S corporation is treated as disposing of the business.
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)—
an S corporation* shall be treated as a partnership, and
the shareholders* of such corporation shall be treated as partners of such partnership.
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.
Source credit: (Added Pub. L. 97–354, § 2, Oct. 19, 1982, 96 Stat. 1682.)
- 1982Enacted · Pub. L. 97-354 · 96 Stat. 1682
A history note hasn’t been published yet. The record shows enactment by Pub. L. 97-354 on 1982-10-19.
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