26 U.S.C. § 1373 - U.S. Code - Unannotated Title 26. Internal Revenue Code § 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)--

(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.