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Internal Revenue Code · 26 U.S.C.

§ 1373. Foreign income

In force Text current through Public Law 119-121 (October 9, 2026) release point 119-121

Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).

Cite as 26 U.S.C. § 1373

At a glance

Read from the text, the source credit and the official notes. Not part of the law.

Status
In force
Added
October 19, 1982 by Pub. L. 97–354
Length
2 subsections · 102 words · about 1 min to read
Cross-references
cites 1; cited by 0 Code sections and 5 other regulations
(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.)

Cross-references

Computed from the citations in the text of Title 26 and 26 CFR.

This section cites 1 other section

Cited in 5 regulations not issued under it

Amendment history

From the source credit and the official notes, newest first.

  1. Added by Pub. L. 97–354

Where it sits in the Code

  1. Subtitle A Income Taxes
  2. Chapter 1 NORMAL TAXES AND SURTAXES
  3. Subchapter S Tax Treatment of S Corporations and Their Shareholders
  4. Part III SPECIAL RULES

Nearby sections

Official notes

Show the Law Revision Counsel's notes (amendments, effective dates)

Editorial Notes

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 of Pub. L. 97–354.

Statutory Notes and Related Subsidiaries

Effective Date

Section 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.