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26 U.S.C. § 1373

Title 26 Chapter 1 Current through PL 116-220 ~1 min read Last updated: March 30, 2026 View on OLRC →
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§ 1373. Foreign income

  • (a) 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) 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.

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