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    Created by Michael Wessels
    1. U.S. Code
    2. Title 26
    3. Subtitle A
    4. CHAPTER 1
    5. Subchapter S
    6. PART III

    § 1373 Foreign income

    (a) S corporation treated as partnership, etc.

    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)—

    (1) an S corporation shall be treated as a partnership, and

    (2) the shareholders of such corporation shall be treated as partners of such partnership.

    (b) Recapture of overall foreign loss

    For purposes of (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.