Their taxable gain will be based on their adjusted basis in the property. 

If there is a treaty for the avoidance of double taxation between the US and that country and that treaty includes rental income from real estate, you can credit the taxes you paid overseas against your foreign taxable income in the US.Of course, you should consult tax specialists if you want to be sure that you declare your taxes correctly according to your own personal situation.

A distribution of an asset from an S corp is taxable at fair market value. 

It depends on your tax bracket" may not be an appropriate answer here.For the most part draws and distributions are a return of capital/decrease tax basis and are not considered taxable income.

If it's not in a Roth, it will be taxable as a traditional IRA distribution as if it were cash at your personal tax rate.

Brain, we can tell you don't have good support here. 1) Transferring/Contributing to the LLC is a non-taxable transition.

Invest to hold with cash flow and don’t trigger taxable events.

These would simply be to determine your taxable gain.You will however have depreciation recapture taxes due, for the period it was a rental, whether you claimed it or not. 

@Ross Y.With everything you described in detail regarding your spouse already actively managing your rentals and being able to properly qualify as a RE Professional (included spending more than 750 hrs/yr$ in that role, yes, your Cost Segregation (including any first year bonus depreciation) can offset your other W2 taxable income.

Minimal HOA.Assuming that rent, 20% down payment, 50% vacancy rate, the cash flow would not be super, but one of the main reasons for my interest in real estate in the immediate present is the effect in reducing our taxable income, rather than for providing replacement income.