§ 1373 Foreign income

OLRC 119-134 · eCFR 2026-10-19

Enacted 1982 · Pub. L. 97-354 Amended · 0 Acts

1982(a) S corporation treated as partnership, etc.(b) Recapture of overall foreign loss
Prior provisions 1
  • 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 of Pub. L. 97–354.
Connections Cited by 0 · Cites 1
    § 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)—

    Cited by 2

      (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 by 4