I was an expat in Thailand for 10 years before returning home to the US. I returned to the US in 2012 with my wife and children. My wife is the owner of several land and residence parcels in Thailand. Her ownership pre-dates both our marriage and her acquiring her Resident Alien (Green Card) status here in the US. She is considering selling some of her holdings in order to buy commercial property here in the US, in order to start a business.

My question is, given that we will have to pay Thai transfer taxes (very small) and Thai Capital Gains taxes (very small), are we liable for any US Capital Gains taxes should she sell her land?

A tax treaty exists between Thailand and the US, but my reading of it leaves me unclear. Thank You for taking the time to respond.

Thailand - Tax Treaty Documents