Since seller is in need of cash, and buyer doesn’t really want to own that painting (it stays put), I trust a $200MM price of a painting also works to assign some other asset through a different transaction. Want to change title to that building, but don’t want to pay a big transfer tax? I’ll pay you the “FMV” for the painting which is held in a low tax jurisdiction, and you’ll sell me your building in a higher-tax jurisdiction for a song.
