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.