(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.
Cited in 5 Tax Court opinions, 0 orders, and 0 briefs.
Current through Pub. L. 119-102 (2026-07-12).
← Back to Internal Revenue Code
This is a Docket.tax digital transcription provided for reference only and may lag the very latest amendments — always confirm against the official U.S. Code linked above. Docket.tax is an independent tool, not affiliated with, endorsed by, or operated by the Office of the Law Revision Counsel or the U.S. Tax Court.