Unfortunately, yes, you owe tax on the gain. As a resident, your income is "worldwide income subject to tax."
Report Worldwide Income. By law, U.S. citizens and residents must report their worldwide income. This includes income from foreign trusts and foreign bank and securities accounts.
Property outside the US does not qualify for a like-kind exchange.
What property qualifies for a Like-Kind Exchange?
Both the
relinquished property you sell and the replacement property you buy must meet
certain requirements.
Both properties
must be held for use in a trade or business or for investment.
Property used primarily for personal use, like a primary residence or a second
home or vacation home, does not qualify for like-kind exchange treatment.
Both properties
must be similar enough to qualify as "like-kind." Like-kind
property is property of the same nature, character or class. Quality or
grade does not matter. Most real estate will be like-kind to other real estate.
For example, real property that is improved with a residential rental house is
like-kind to vacant land. One exception for real estate is that property
within the United States is not like-kind to property outside of the United
States. Also, improvements that are conveyed without land are not of like
kind to land.
