Section 952. Tax imposed

(a) A tax is hereby imposed on the transfer of the
  New York estate by every deceased individual who at his or her death was
  a  resident  of New York state. The tax imposed by this subsection shall
  be an amount equal to the maximum amount allowable against  the  federal
  estate  tax as a credit for state death taxes under section two thousand
  eleven of the internal revenue code.
    (b) If the transfer of any part of the estate of a  deceased  resident
  includes  real  or  tangible  personal  property  having an actual situs
  outside New York state, the  tax  imposed  by  subsection  (a)  of  this
  section  shall  be  reduced  by  an amount determined by multiplying the
  maximum amount of  the  federal  credit  for  state  death  taxes  by  a
  fraction,  the numerator of which is the decedent's federal gross estate
  reduced by his or her New York gross estate and the denominator of which
  is his or her federal gross estate.