CHAPTER 1— NORMAL TAXES AND SURTAXES›Subchapter S— Tax Treatment of S Corporations and Their Shareholders›PART III— SPECIAL RULES

§ 1373. Foreign income

26 U.S.C. Subtitle A — Income Taxes (Internal Revenue Code) · 2026 edition · updated 2026-10-03 · United States

(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.

(Added Pub. L. 97–354, § 2, Oct. 19, 1982, 96 Stat. 1682.)

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▸Contents — 26 U.S.C. Subtitle A — Income Taxes (Internal Revenue Code)

26 U.S.C. Subtitle A — Income Taxes (Internal Revenue Code)

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