ART AS AN ENGINE OF WEALTH CREATION

Did you think De Centrale would be the only publication not to write about Epstein? Then you were mistaken. But we approach it differently.

The most unanswered question is not whom he knew or where he stayed. The real question is: how did he become rich? Jeffrey Epstein was paid hundreds of millions of dollars to provide financial and tax advice to people who themselves are financial geniuses. So what exactly was his added value?

The example of art says a great deal.

In February 2026, Forbes published an extensive article about private-equity magnate Leon Black and the financial architecture behind his art collection. According to the reporting, Black paid Jeffrey Epstein approximately $170 million over roughly six years for financial and tax advice. A separate independent review by the international law firm Dechert concluded that Epstein received $158 million between 2012 and 2017 for advice related to tax structures, estate planning and asset management.

These are not ordinary advisory fees. They reflect strategic structuring at the highest level of wealth.

The Art Collection as a Financial Instrument

Leon Black had long been known as one of the world’s most formidable art collectors. His holdings included museum-quality masterpieces. But according to documents referenced by Forbes, the collection was not treated merely as a passion project — it was structured as a financial asset base.

In 2014, entities controlled by Black reportedly pledged approximately $1 billion worth of art as collateral to Bank of America. By 2017, the value of the collateralized works had risen to $1.4 billion.

Documents titled “Art Partnership Inventory,” “Collateral,” and “All Art” reportedly detailed:

– the acquisition cost of each piece
– the appraised value (including valuations attributed to Christie’s)
– the unrealized gain
– which works were pledged as collateral

As of December 31, 2015, Black-controlled entities reportedly had $631 million in outstanding loans, of which $565 million was attributed to a single entity, Narrows LLC.

The collection itself was reportedly valued at approximately $3 billion in 2016, with around $1 billion in unrealized gains.

That is the core of “Buy, Borrow, Die.”

Buy
Acquire assets that appreciate. As long as no sale occurs, there is generally no realized capital gains tax.

Among the works listed with both purchase price and 2016 appraised value were:

Paul Cézanne – Le Château Noir
Purchased for $11.5 million; appraised at $50 million

Kazimir Malevich – Extended Plane (Plan en extension)
Purchased for $15.5 million; appraised at $50 million

Claude Monet – Nympheas
Purchased for $22.5 million; appraised at $45 million

Piet Mondrian – Composition C with Grey and Red
Purchased for $2.7 million; appraised at $40 million

Constantin Brâncuși – La Muse
Purchased for $10.5 million; appraised at $40 million

Fernand Léger – Femme courant
Purchased for $16 million; appraised at $40 million

Paul Cézanne – La carrière de Bibémus
Purchased for $7.5 million; appraised at $35 million

Pablo Picasso – Buste de femme
Purchased for $9.5 million; appraised at $30 million

Edvard Munch – Melancholy
Purchased for $11 million; appraised at $30 million

Henri Matisse – Marocaine en jaune (Zorah en jaune)
Purchased for $10 million; appraised at $25 million

J.M.W. Turner – Goldau
Purchased for $1.3 million; appraised at $20 million

Rembrandt van Rijn – An old bearded man, seated
Purchased for $2.45 million; appraised at $18 million

In many cases, the unrealized gains ran into tens of millions of dollars per work. That value remained on paper — but could be monetized through borrowing.

Borrow
Instead of selling — which in the United States can trigger federal capital gains tax of up to 28% on collectibles — the owner borrows against the appraised value.

A loan is not income. It is a liability. Therefore, the borrower gains liquidity without triggering a taxable sale.

Forbes characterized this as a practical application of the “Buy, Borrow, Die” strategy popularized by Professor Edward McCaffery.

Die
In the United States, inherited property generally receives a step-up in basis to fair market value at the date of death. This can eliminate income tax on lifetime appreciation. Estate tax may still apply depending on the size of the estate, but the capital gain itself may effectively disappear for income tax purposes.

This makes the strategy particularly powerful in the U.S.

Reputation, Institutions and Cultural Influence

Forbes also described how Black strategically used his collection in connection with major cultural institutions.

He served as chairman of the board of the Museum of Modern Art (MoMA) from 2018 to 2021. As of 2014, he had pledged $23.5 million worth of art as future gifts to MoMA. In 2018, he donated $40 million in cash, after which the museum’s film center was named in honor of him and his wife.

Works from his collection were exhibited at major institutions, including the Metropolitan Museum of Art. Two drawings shown in a Met exhibition were reportedly valued at a combined $98 million in 2017.

Art thus functioned not only as financial collateral, but also as reputational capital.

Epstein’s Position in the New York Museum Ecosystem

Epstein’s formal titles within museums were limited, but his influence operated through proximity to ultra-wealthy collectors and trustees. By advising individuals deeply embedded in the boards and donor circles of institutions such as MoMA and the Metropolitan Museum of Art, Epstein gained indirect access to the cultural establishment.

His role appears less curatorial and more structural. Through trusted relationships with major collectors, he participated in shaping how large art holdings were organized, valued and potentially leveraged. In elite art ecosystems, influence often travels through private advisory channels rather than public institutional roles.

The added value, therefore, may not have been in obscure tax tricks, but in structuring wealth in a way that transformed aesthetic assets into balance-sheet instruments.

And Belgium?

Belgium presents a different fiscal landscape.

VAT
Belgium applies three VAT rates: 21%, 12% and 6%. Many art transactions now benefit from the reduced 6% rate, while the margin scheme has been more strictly limited.

Capital Gains
Belgium does not impose a general capital gains tax on private individuals when assets are sold within the normal management of private wealth. However, if transactions are deemed speculative or professional, taxation may apply.

Inheritance Tax
At death, inheritance tax plays the central role. It is regionally administered (Flanders, Wallonia, Brussels) and progressive, reaching up to 30% in direct line and higher for more distant heirs.

Belgium does not rely on a U.S.-style step-up mechanism as the core tax feature. The fiscal emphasis shifts from income tax elimination to inheritance tax planning.

The Core Question

What was Epstein’s added value?

Not necessarily a secret loophole.
Not a magical tax device.

His value appears to have been structural: organizing assets so that they could function as financial leverage, connecting art, banks and institutions, and advising on frameworks that allowed vast appreciation to be mobilized without traditional sale events.

Art, in this context, was not passive luxury.

It became strategic capital.

And in the right legal and fiscal environment, it becomes financial capital.