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Patrick, Im going to have to study your cites and the treaty. I'm not seeing double taxation here.

Marie, The departure tax paid to Canada should be treated as a creditable tax as it meets the tests under Reg. § 1.901-2(a)(3) and (b).  This is alluded to in the Technical Explanation which states: If the Canadian resident is also a U.S. citizen at ...

Thanks, Beth! I'd love it to be a basis adjustment but I'm not sure.  Feels like compensation for a partial sale of land associated with the primary residence (taxed?) as well as payment for a casualty loss of some sort due to loss of value.  Right ...