Step-up for rental and article XIII (7) of the treaty “at any time”

[Anna2024]

Hello,

After reading many posts, I’m still not sure if my understanding is correct.

When you leave Canada owning a Canadian principal residence at the time of your departure, you (a Canadian citizen only) will have a natural step-up of basis to FMV at the time of departure without reporting any other treaty positions (no form 8833 is needed).
Later, you begin to rent your principal residence.
When you report your rental income to the IRS, you use the stepped-up value to calculate depreciation.
If the moment of change-in-use occurs the year after your departure, is it possible to add to your tax return form 8833 to step-up the value of your rental at the moment of the change-in-use – article XIII (7)?
When I read the treaty, it seems possible, especially when the treaty uses words “at any time”. When I read IRS explanations, they talk only about deemed dispositions upon departure and departure tax. Do they just omit other scenarios because they are not common?
In some cases, it may be interesting to declare “change-in-use” on the Canadian side to crystallize the value of your property and it would be easier to use the same adjusted basis on both sides of the border while reporting your rental income. It would also be possible to use the appraisal made for CRA, at the time of change-in-use, on the US side, instead of paying for another appraisal at the date of departure from Canada.

All the suggestions are greatly appreciated, as always.