Digging into this again to get you a reference and it looks like I am wrong.  There is a mark-to-market regime, but (1) I don't qualify under the 3 tests, and (2) even if I did there is a $600,000 reduction and an $821,000 exclusion.... looks really complicated to work out though... but worth it to stop filing US taxes. 

 Hire a CPA. They are worth it, if only for the liability protection they provide if they give you bad advice