26 U.S. Code § 1373 - Foreign income

(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.)
Prior Provisions

A prior section 1373, added Pub. L. 85–866, title I, § 64(a),Sept. 2, 1958, 72 Stat. 1652; amended Pub. L. 89–389, § 2(b)(3),Apr. 14, 1966, 80 Stat. 114; Pub. L. 91–172, title III, § 301(b)(10),Dec. 30, 1969, 83 Stat. 586, related to taxation of corporation undistributed taxable income to shareholders, prior to the general revision of this subchapter by section 2 ofPub. L. 97–354.
Effective Date

Section applicable to taxable years beginning after Dec. 31, 1982, see section 6(a) ofPub. L. 97–354, set out as a note under section 1361 of this title.

The table below lists the classification updates, since Jan. 3, 2012, for this section. Updates to a broader range of sections may be found at the update page for containing chapter, title, etc.

The most recent Classification Table update that we have noticed was Tuesday, August 13, 2013

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26 USCDescription of ChangeSession YearPublic LawStatutes at Large


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