26 U.S.C. § 1373
§ 1373. Foreign income
No plain-English explainer yet. Below is the official text. Explainers are being added section by section.
The law as written
Current through Public Law 119-102. Amendment notes omitted.
(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 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.