((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.