Canadian departure tax impact on future cost basis?

[TLchap]

Let's say I return to the U.S. after more than 5 years in Canada as PR, and have to calculate CRA departure tax based on the deemed disposition appreciation of my home or other assets in the U.S. over those 5+ years. Can I at least use the determined FMV at that time as the cost basis for U.S. CG calculation when I eventually sell?

[nelsona]

Review Rev Proc 10-19 fo details, but what you will likely need to do is file an election to treat the US as property as being "sold" for US purposes, to claim the Cdn tax as a credit in that year.

[TLchap]

That's helpful, thank you.