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)—
an S corporation shall be treated as a partnership, and
the shareholders of such corporation shall be treated as partners of such partnership.
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.
Pub. L. 97–354, § 296 Stat. 1682(Added , , .)
Editorial Notes
Prior Provisions
Pub. L. 85–866, title I, § 64(a)72 Stat. 1652Pub. L. 89–389, § 2(b)(3)80 Stat. 114Pub. L. 91–172, title III, § 301(b)(10)83 Stat. 586section 2 of Pub. L. 97–354A prior section 1373, added , , ; amended , , ; , , , related to taxation of corporation undistributed taxable income to shareholders, prior to the general revision of this subchapter by .
Statutory Notes and Related Subsidiaries
Effective Date
section 6(a) of Pub. L. 97–354section 1361 of this titleSection applicable to taxable years beginning after , see , set out as a note under .