Managing cap gains tax liability cross border

[safgas]

Dual citizen US/Canada / 64 years old
Married – husband lives in Washington state
Have been working in Canada for 9 years (Arrived Feb 2015) and plan to leave for WA next week.
$450k USD capital gains on taxable US Vanguard Mutual Fund over 9 years in Canada
2024 potential capital gains tax $120k CAD

I've spoken with a cpa about deemed disposition and adjusting the cost basis in the US for actual sales with form 8833. I believe I will be selling this a little bit at a time for years. Will I always need to engage a cross border CPA? One advantage of deemed disposition is the chance to unwind should I return to Canada. I would like to come back to Canada but currently do not have plans.

I am wondering if selling the fund on the Canadian side and rebuying on US side is cleaner and easier to manage going forward.

[nelsona]

You also have the choice of posting security, and then only paying the exit tax as you sell the investments (CRA Form T1244).

If bumping up of cost value ends up being your only complication in your US return, I would think you would not need a tax specialist to do this. Rev Proc 2010-19 is pretty simple to apply year after year.

If you sell you can't unwind, of course.