Will Treaty provide a bump-up in the cost basis for property

[szbjsh]

I plan to rent out my principle residence in Canada when I become a non-resident of Canada and a resident of the U.S when moving to south of the border. Say I want to sell my Canadian property in a 10 years while I am a US resident. Will the Treaty provide a bump-up in the cost basis of the property as of the date when I become a non-resident of Canada and a resident of the U.S?

My original purchase price is $400K;
FMV is $500K when I become US resident, emigrate from Canada;
FMV is $800K when I sell in 10 years.

Will US capital gain be based on 800K-500K=300K or 800K-400K=400K? Thanks!

[nelsona]

Yes, the treaty provides for this. Article XIII.6