2012 US Code
Title 26 - Internal Revenue Code
Subtitle A - Income Taxes (§§ 1 - 1564)
Chapter 1 - NORMAL TAXES AND SURTAXES (§§ 1 - 1400U-3)
Subchapter S - Tax Treatment of S Corporations and Their Shareholders (§§ 1361 - 1379)
Part III - SPECIAL RULES (§§ 1371 - 1375)
Section 1373 - Foreign income
| Publication Title | United States Code, 2012 Edition, Title 26 - INTERNAL REVENUE CODE |
| Category | Bills and Statutes |
| Collection | United States Code |
| SuDoc Class Number | Y 1.2/5: |
| Contained Within | Title 26 - INTERNAL REVENUE CODE Subtitle A - Income Taxes CHAPTER 1 - NORMAL TAXES AND SURTAXES Subchapter S - Tax Treatment of S Corporations and Their Shareholders PART III - SPECIAL RULES Sec. 1373 - Foreign income |
| Contains | section 1373 |
| Date | 2012 |
| Laws in Effect as of Date | January 15, 2013 |
| Positive Law | No |
| Disposition | standard |
| Source Credit | Added Pub. L. 97-354, §2, Oct. 19, 1982, 96 Stat. 1682. |
| Statutes at Large References | 72 Stat. 1652 80 Stat. 114 83 Stat. 586 96 Stat. 1682 |
| Public Law References | Public Law 85-866, Public Law 89-389, Public Law 91-172, Public Law 97-354 |
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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 lossFor 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 ProvisionsA 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.
Effective DateSection applicable to taxable years beginning after Dec. 31, 1982, see section 6(a) of Pub. L. 97–354, set out as a note under section 1361 of this title.
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