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Yes it most certainly is.

In this scenario, what is the taxable base ?

You would need a valuation for the painting you disposed of. The fact that you never actually received USD is irrelevant.

I had this problem in 2018 - I bought BTC in 2017 before the boom, exchanged a bunch for ETH at the peak of 2018, and then rode the ETH all the way back down. I had to pay a bunch of taxes on the BTC gains I “realised” even though I didn’t get any actual cash out. I had to pick a price settle for BTC/USD on the day I bought ETH.

Same in French law if you move a company abroad: You need a valuation on the day of departure, and are taxed on it, even if you don’t realize the gains.

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