“We are still in the early days of the so-called great wealth transfer,” says the lawyer Pierre Valentin, the joint head of art law at Fieldfisher. But a number of other states, including New York, have a separate estate tax with their own thresholds and rates. “Often you do a bit of a pick and mix… some conditional exemption, some tax to pay, and an offer in lieu of inheritance tax,” Philips says. While not directly related to IHT, the French Parliament has been debating a reform to replace the real estate wealth tax (IFI) with a broader tax on “unproductive wealth”, which could include art, antiques, and collectibles. Schemes like dation en paiement and charitable donations are gaining attention as the great wealth transfer gets underway, Gabizon says.