26 U.S.C. § 1373
Verified against govinfo.gov as of June 20, 2026View official text on govinfo.gov ↗
- (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)—
- (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.