I'm kind of in the same situation, thinking about upgrading my Note 8. I've got a Note 3 for my phone, and I've been running the Note 3 ROM port (which is pretty awesome) for a while now, so... kind of redundant. I've liked my Note 8 a lot since the day I got it, but the Note 3 just destroys it performance-wise. I've been getting more into gaming lately, and there the difference is particularly noticeable. Additionally, I'm sure many are aware that many games simply devour the battery. Yesterday I think I went from fully charged down to the teens playing The Walking Dead (really cool game and totally ideal for a touch screen vs. PC version) for about an hour!
Also, I have to say that having 32 gigs of onboard storage is incredibly nice. I've got a ton of apps including several GB+ games on each device. On the Note 8 w/ 16 GB, I have 38(!) app data files moved to my extSdCard via FolderMount. On the Note 3 with 32 gigs, I have more apps installed overall, but with the exception of maybe a gig worth of apps to external storage (I'm still on 4.3, so for many apps in app info there's a "Move to SD" button), everything is straight-up installed on internal storage with a few gigs to spare.
I almost would prefer a Tab to a Note, because if I have an s-pen, I'm super reluctant to install non-TW ROMs, but right now I find the new Note 10.1 to be the most compelling device, mostly due to the 3 GB ram (and the 32 GB storage). I'd find the Tab Pro 8.4 much more compelling if only a 32 GB version was available. Anyways, I took a look at Swappa and it looks like there are new Note 10.1's for pretty reasonable prices. I just wish the Nexus 8 was more than vapor-ware at the moment, but I think I'll have to wait until some solid information emerges before making any final upgrade decisions (external SD port PLEASE!)