26Title 26The US tax code, read & explained

26 U.S.C. § 1373

§ 1373. Foreign income

102 words

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No plain-English explainer yet. Below is the official text. Explainers are being added section by section.

History

Added in 1982 by the Public Law 97-354. Last changed October 19, 1982 by the Public Law 97-354.

Every change, newest first (1)
  1. October 19, 1982Public Law 97-354 · added this section

The law as written

Current through Public Law 119-102. Amendment notes omitted.

Structure

  1. (a) S corporation treated as partnership, etc.
  2. (b) Recapture of overall foreign loss
(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.