Definitions for estate tax apportionment

In this part: "Apportionable estate" means the value of the gross estate as finally determined for purposes of the estate tax to be apportioned, reduced by: (1) Any claim or expense allowable as a deduction for purposes of the tax; (2) The value of any interest in property that, for purposes of the tax, qualifies for a marital or charitable deduction or is otherwise deductible or exempt; and (3) Any amount added to the decedent's gross estate because of a gift tax on transfers made before death. "Estate tax" means a federal, state, or foreign tax imposed because of the death of an individual and any interest and penalties associated with the tax. "Estate tax" does not include an inheritance tax, income tax, or generation-skipping transfer tax incurred on a direct skip taking effect at death. "Gross estate" means, with respect to an estate tax, all interests in property subject to the tax. "Person" means an individual, corporation, business trust, estate, trust, partnership, limited liability company, association, joint venture, public corporation, government, governmental subdivision, agency, or instrumentality, or any other legal or commercial entity. "Ratable" or "ratably" means apportioned or allocated pro rata, according to the relative values of interests to which the term is applied. "Time-limited interest" means an interest in property that terminates on a lapse of time or on the occurrence or nonoccurrence of an event or that is subject to the exercise of discretion that could transfer a beneficial interest to another person. "Time-limited interest" does not include a cotenancy unless the cotenancy itself is a time-limited interest. "Value" means, with respect to an interest in property, fair market value as finally determined for purposes of the estate tax that is to be apportioned, reduced by any outstanding debt secured by the interest without reduction for taxes paid or required to be paid or for any special valuation adjustment.