(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.