And of course there’s ways to solve this: tax the land at disposition. You don’t need to collect on the estate tax for land holdings as dollars at time of inheritance, you can just drop fractional ownership into a trust c/o the IRS and even retain right of first refusal if you should be able to pay it off in time. This is how the IRS already handles illiquid assets if an American chooses to expatriate: you get the choice to pay in cash or fractional ownership in trust.