reversing Treaty election XIII(7)

[crossbordernut]

If a Canadian who moved to the US already filed their US tax return for the year of the move with the treaty election under XIII(7) to bump up ACB to FMV on all assets subject to departure tax, do you have any idea if the US return can be amended after the fact and the bump-up election reversed?

[nelsona]

If it is simply to correct an entry on your election (ie. wrong FMV for an investment), or if your election was invalid (ie. your total net deemed dispositions was for a loss) then a 1040-X would suffice, but to "un-elect" a valid election would be different story. The election is irrevocable, without consent of IRS Commissioner. See IRS Rev. Proc. 2010-19

Can I ask under what circumstances you wish to reverse it? I'm not seeing a circumstance in which that would benefit you.