Michael and Thomas Connelly were the sole shareholders in Crown C Supply, a small building supply corporation. The brothers entered into an agreement to ensure that Crown would stay in the family if either brother died. Under that agreement, the surviving brother would have the option to purchase the deceased brother’s shares. If he declined, Crown itself would be required to redeem (i.e., purchase) the shares. To ensure that Crown would have enough money to redeem the shares if required, it obtained $3.5 million in life insurance on each brother. After Michael died, Thomas elected not to purchase Michael’s shares, thus triggering Crown’s obligation to do so. Michael’s son and Thomas agreed that the value of Michael’s shares was $3 million, and Crown paid the same amount to Michael’s estate. As the executor of Michael’s estate, Thomas then filed a federal tax return for the estate, which reported the value of Michael’s shares as $3 million. The Internal Revenue Service (IRS) audited the return. During the audit, Thomas obtained a valuation from an outside accounting firm. That firm determined that Crown’s fair market value at Michael’s death was $3.86 million, an amount that excluded the $3 million in insurance proceeds used to redeem Michael’s shares on the theory that their value was offset by the redemption obligation. Because Michael had held a 77.18% ownership interest in Crown, the analyst calculated the value of Michael’s shares as approximately $3 million ($3.86 million x 0.7718). The IRS disagreed. It insisted that Crown’s redemption obligation did not offset the life-insurance proceeds, and accordingly, assessed Crown’s total value as $6.86 million ($3.86 million + $3 million). The IRS then calculated the value of Michael’s shares as $5.3 million ($6.86 million x 0.7718). Based on this higher valuation, the IRS determined that the estate owed an additional $889,914 in taxes. The estate paid the deficiency and Thomas, acting as executor, sued the United States for a refund. The District Court granted summary judgment to the Government. The court held that, to accurately value Michael’s shares, the $3 million in life-insurance proceeds must be counted in Crown’s valuation. The Eighth Circuit affirmed.

Held: A corporation’s contractual obligation to redeem shares is not necessarily a liability that reduces a corporation’s value for purposes of the federal estate tax.

  When calculating the federal estate tax, the value of a decedent’s shares in a closely held corporation must reflect the corporation’s fair market value. And, life-insurance proceeds payable to a corporation are an asset that increases the corporation’s fair market value. The question here is whether Crown’s contractual obligation to redeem Michael’s shares at fair market value offsets the value of life-insurance proceeds committed to funding that redemption.

  The answer is no. Because a fair-market-value redemption has no effect on any shareholder’s economic interest, no hypothetical buyer purchasing Michael’s shares would have treated Crown’s obligation to redeem Michael’s shares at fair market value as a factor that reduced the value of those shares. At the time of Michael’s death, Crown was worth $6.86 million—$3 million in life-insurance proceeds earmarked for the redemption plus $3.86 million in other assets and income-generating potential. Anyone purchasing Michael’s shares would acquire a 77.18% stake in a company worth $6.86 million, along with Crown’s obligation to redeem those shares at fair market value. A buyer would therefore pay up to $5.3 million for Michael’s shares ($6.86 million x 0.7718)—i.e., the value the buyer could expect to receive in exchange for Michael’s shares when Crown redeemed them at fair market value. Crown’s promise to redeem Michael’s shares at fair market value did not reduce the value of those shares.

  Thomas’s efforts to resist this straightforward conclusion fail. He views the relevant inquiry as what a buyer would pay for shares that make up the same percentage of the less-valuable corporation that exists after the redemption. For calculating the estate tax, however, the whole point is to assess how much Michael’s shares were worth at the time that he died—before Crown spent $3 million on the redemption payment. See 26 U. S. C. §2033 (defining the gross estate to “include the value of all property to the extent of the interest therein of the decedent at the time of his death”). A hypothetical buyer would treat the life-insurance proceeds that would be used to redeem Michael’s shares as a net asset.

  Thomas’s argument that the redemption obligation was a liability also cannot be reconciled with the basic mechanics of a stock redemption. He argues that Crown was worth only $3.86 million before the redemption, and thus that Michael’s shares were worth approximately $3 million ($3.86 million x 0.7718). But he also argues that Crown was worth $3.86 million after Michael’s shares were redeemed. See Reply Brief 6. Both cannot be right: A corporation that pays out $3 million to redeem shares should be worth less than before the redemption.

  Finally, Thomas asserts that affirming the decision below will make succession planning more difficult for closely held corporations. But the result here is simply a consequence of how the Connelly brothers chose to structure their agreement. Pp. 5–9.

70 F. 4th 412, affirmed.

 Thomas, J., delivered the opinion for a unanimous Court.

Petitioner Truck Insurance Exchange is the primary insurer for companies that manufactured and sold products containing asbestos. Two of those companies, Kaiser Gypsum Co. and Hanson Permanente Cement (Debtors), filed for Chapter 11 bankruptcy after facing thousands of asbestos-related lawsuits. As part of the bankruptcy process, the Debtors filed a proposed reorganization plan (Plan). That Plan creates an Asbestos Personal Injury Trust (Trust) under 11 U. S. C. §524(g), a provision that allows Chapter 11 debtors with substantial asbestos-related liability to fund a trust and channel all present and future asbestos-related claims into that trust. Truck is contractually obligated to defend each covered asbestos personal injury claim and to indemnify the Debtors for up to $500,000 per claim. For their part, the Debtors must pay a $5,000 deductible per claim, and assist and cooperate with Truck in defending the claims. The Plan treats insured and uninsured claims differently, requiring insured claims to be filed in the tort system for the benefit of the insurance coverage, while uninsured claims are submitted directly to the Trust for resolution.

   Truck sought to oppose the Plan under §1109(b) of the Bankruptcy Code, which permits any “party in interest” to “raise” and “be heard on any issue” in a Chapter 11 bankruptcy. Among other things, Truck argues that the Plan exposes it to millions of dollars in fraudulent claims because the Plan does not require the same disclosures and authorizations for insured and uninsured claims. Truck also asserts that the Plan impermissibly alters its rights under its insurance policies. The District Court confirmed the Plan. It concluded, among other things, that Truck had limited standing to object to the Plan because the Plan was “insurance neutral,” i.e., it did not increase Truck’s prepetition obligations or impair its contractual rights under its insurance policies. The Fourth Circuit affirmed, agreeing that Truck was not a “party in interest” under §1109(b) because the plan was “insurance neutral.”

Held: An insurer with financial responsibility for bankruptcy claims is a “party in interest” under §1109(b) that “may raise and may appear and be heard on any issue” in a Chapter 11 case. Pp. 7–15.

  (a) Section 1109(b)’s text, context, and history confirm that an insurer such as Truck with financial responsibility for a bankruptcy claim is a “party in interest” because it may be directly and adversely affected by the reorganization plan. Pp. 7–13.

   (1) Section 1109(b)’s text is capacious. To start, it provides an illustrative but not exhaustive list of parties in interest, all of which are directly affected by a reorganization plan either because they have a financial interest in the estate’s assets or because they represent parties that do. This Court has observed that Congress uses the phrase “party in interest” in bankruptcy provisions when it intends the provision to apply “broadly.” Hartford Underwriters Ins. Co. v. Union Planters Bank, N. A., 530 U. S. 1, 7. This understanding aligns with the ordinary meaning of the terms “party” and “interest,” which together refer to entities that are potentially concerned with, or affected by, a proceeding. The historical context and purpose of §1109(b) also support this interpretation. Congress consistently has acted to promote greater participation in reorganization proceedings. That expansion of participatory rights continued with the enactment of §1109(b). Broad participation promotes a fair and equitable reorganization process. Pp. 7–11.

   (2) Applying these principles, insurers such as Truck are parties in interest. An insurer with financial responsibility for bankruptcy claims can be directly and adversely affected by the reorganization proceedings in myriad ways. In this case, for example, Truck will have to pay the vast majority of the Trust’s liability, and §524(g)’s channeling injunction, which stays any action against the Debtors, means that Truck would stand alone in carrying that financial burden. According to Truck, however, a plan that lacks the disclosure requirements for the uninsured claims risks exposing Truck to millions of dollars in fraudulent tort claims. The Government frames Truck’s interest slightly differently, but the result is the same: Where a proposed plan “allows a party to put its hands into other people’s pockets, the ones with the pockets are entitled to be fully heard and to have their legitimate objections addressed.” In re Global Indus. Technologies, Inc., 645 F. 3d 201, 204.

  Providing Truck an opportunity to be heard is consistent with §1109(b)’s purpose of promoting a fair and equitable reorganization process. Here, the Plan eliminates the Debtors ongoing liability, and claimants similarly have little incentive to propose barriers to their ability to recover from Truck. Truck may well be the only entity with an incentive to identify problems with the Plan. Pp. 11–13.

  (b) The Court of Appeals looked exclusively at whether the Plan altered Truck’s contract rights or its “quantum of liability.” This approach, known as the “insurance neutrality” doctrine, is conceptually wrong and makes little practical sense. Conceptually, the doctrine conflates the merits of an objection with the threshold party in interest inquiry. The §1109(b) inquiry asks whether the reorganization proceedings might affect a prospective party, not how a particular reorganization plan actually affects that party. Practically, the doctrine is too limited in its scope. By focusing on the insurer’s prepetition obligations and policy rights, the doctrine wrongly ignores all the other ways in which bankruptcy proceedings and reorganization plans can alter and impose obligations on insurers and debtors. The fact that Truck’s financial exposure may be directly and adversely affected by a plan is sufficient to give Truck a right to voice its objections. Finally, in resisting the text of §1109(b), the Debtors emphasize the risks of allowing “peripheral parties” to derail a reorganization. This “parade of horribles” argument cannot override the statute’s text, and in any event, §1109(b) provides parties in interest only an opportunity to be heard—not a vote or a veto in the proceedings. In all events, the Court today does not opine on the outer bounds of §1109. Difficult cases may require courts to evaluate whether truly peripheral parties have a sufficiently direct interest to be heard. This case is not one of them because insurers such as Truck with financial responsibility for claims are not peripheral parties. Pp. 13–15.

60 F. 4th 73, reversed and remanded.

 Sotomayor, J., delivered the opinion of the Court, in which all other Members joined, except Alito, J., who took no part in the consideration or decision of the case.

The Indian Self-Determination and Education Assistance Act, 25 U. S. C. §5301 et seq., enables an Indian tribe to enter into a “self-determination contract” with the Indian Health Service to assume responsibility for administering the healthcare programs that IHS would otherwise operate for the tribe. §5321(a)(1). When IHS administers such programs itself, it funds its operations through congressional appropriations and third-party insurance payments. Healthcare programs administered by a tribe under a self-determination contract have a parallel funding structure. First, IHS must provide to the tribe the Secretarial amount, which “shall not be less” than the congressionally appropriated amount that IHS would have used to operate such programs absent the self-determination contract. §5325(a)(1). Second, like IHS when it runs the healthcare programs, a contracting tribe can collect revenue from third-party payers like Medicare, Medicaid, and private insurers. See 42 U. S. C. §§1395qq(a), 1396j(a); 25 U. S. C. §1621e(a). These third-party funds are called “program income” and must be used by the tribe “to further the general purposes of the contract” with IHS. §5325(m)(1).

  The Secretarial amount and program income, however, do not place a contracting tribe on equal footing with IHS. That is because the tribe must incur certain overhead and administrative expenses that IHS does not incur when it runs the healthcare programs. To remedy this funding shortfall, Congress amended ISDA to require IHS to pay the tribe “contract support costs” to cover such “reasonable costs for activities which must be carried on by a [tribe] as a contractor to ensure compliance with the terms of the [self-determination] contract.” §5325(a)(2). Contract support costs eligible for repayment include “direct program expenses for the operation of the Federal program” and “any additional administrative or . . . overhead expense incurred by the [tribe] in connection with the operation of the Federal program, function, service, or activity pursuant to the contract.” §5325(a)(3)(A). Such costs are limited, however, to those “directly attributable to” self-determination contracts. §5326. And no funds are available for “costs associated with any contract . . . entered into between [a tribe] and any entity other than [IHS].” Ibid.

  These cases involve self-determination contracts between IHS and two tribes—the San Carlos Apache Tribe and the Northern Arapaho Tribe. Both Tribes sued the Government for breach of contract, contending that although they used the Secretarial amount and program income to operate the healthcare programs they assumed from IHS under their self-determination contracts, IHS failed to pay the contract support costs they incurred by providing healthcare services using program income. The Ninth and Tenth Circuits concluded that each Tribe was entitled to reimbursement for such costs.

Held: ISDA requires IHS to pay the contract support costs that a tribe incurs when it collects and spends program income to further the functions, services, activities, and programs transferred to it from IHS in a self-determination contract. Pp. 8–18.

 (a) Sections 5325(a)(2) and (a)(3)(A) peg contract support costs to the requirements of a self-determination contract. Section 5325(a)(2) defines contract support costs as “the reasonable costs for activities which must be carried on by a tribal organization as a contractor to ensure compliance with the terms of the contract.” If a tribe therefore must collect and spend program income to ensure compliance with its contract, then the reasonable administrative and overhead costs it incurs in doing so are “contract support costs.”

 Each self-determination contract entered into under ISDA incorporates Section 5325(m)(1), which requires a contracting tribe to use “program income earned . . . in the course of carrying out a self-determination contract” to “further the general purposes of the contract.” See §§5329(a)(1), (c). The purposes of the contract are the “functions, services, activities, and programs” transferred from IHS to the tribe in its contract. See §5329(c) (requiring a “purpose” clause listing the “functions, services, activities, and programs” to be transferred from IHS to the tribe). When the tribe uses program income to further the functions, services, activities, and programs it assumed from IHS and incurs reasonable costs for required support services, those costs are “contract support costs” under Section 5325(a)(2).

 Those costs are also “eligible costs for the purposes of receiving funding” under Section 5325(a)(3)(A), which specifies that both direct and indirect contract support costs may be reimbursed. Direct contract support costs are “direct program expenses for the operation of the Federal program that is the subject of the contract.” §5325(a)(3)(A)(i). When a tribe spends program income to further the functions, services, activities, and programs that it agrees to administer in IHS’s stead under its self-determination contract and incurs direct contract support costs, those costs are incurred “for the operation of the Federal program that is the subject of the contract” and are thus eligible for reimbursement. Indirect contract support costs are “any additional administrative or other expense incurred by [a tribe] in connection with the operation of the Federal program, function, service, or activity pursuant to the contract.” §5325(a)(3)(A)(ii). When a tribe spends program income to further the functions, services, activities, and programs that it assumes from IHS and incurs indirect contract support costs, those costs are incurred “in connection with the operation of the Federal program, function, service, or activity pursuant to the contract” and are thus eligible for reimbursement.

 The self-determination contracts of the Tribes require them to collect program income. Once the Tribes collect such income, they are contractually required to use it. The Tribes aver that they have collected and spent program income as required by their contracts to carry out the operations IHS transferred to them. The reasonable direct and indirect contract support costs they incurred as a result are eligible for repayment under Section 5325(a) because they were incurred to “ensure compliance with the terms of the contract,” §5325(a)(2), and “for the operation of” and “in connection with the operation of” the “Federal program” they assumed from IHS, §5325(a)(3)(A). Pp. 8–12.

 (b) The limitations in Section 5326 do not preclude payment of costs incurred by the required spending of program income under a self-determination contract. When a tribe spends program income to further the healthcare programs it assumes from IHS and incurs contract support costs, the costs it incurs are “directly attributable” to the self-determination contract. And such costs are not “associated with” any contract between the tribe and a third party. They are instead “associated with” the contract that requires the work that generates the support costs—the self-determination contract. The history of Section 5326 confirms this analysis. Pp. 12–14.

 (c) The Government’s arguments to the contrary find no support in ISDA’s text. Pp. 14–16.

  (1) Contrary to the Government’s assertion, nothing in Section 5325(a)(2) suggests that contract support costs are limited to programs funded by the Secretarial amount. In fact, Section 5325(a)(2) defines contract support costs as tied to “the terms of the contract,” which require tribes to fund programs with program income. Nor does the Government cite any statutory text to support its assertion that the contract support costs of spending program income are ineligible for repayment under Section 5325(a)(3)(A) because the “Federal program” comprises only the Secretarial amount. That provision refers to eligible costs for the operation of the “Federal program” without limiting that program to the Secretarial amount. Pp. 14–15.

   (2) The Government also argues that tribes should not get contract support costs for spending program income because that would give them flexibility to spend such income on a broader range of activities than IHS can. But the differences cited by the Government do not withstand scrutiny. First, the difference between IHS’s and a tribe’s ability to offer healthcare services to non-Indians is irrelevant because both must make the same determination before either can offer such services: Whether such services will result in a denial or diminution of services to eligible Indians. §§1680c(c)(1)(B), (c)(2). Next, although IHS must “first” use Medicare and Medicaid proceeds to ensure compliance with those programs, a tribe must also use such proceeds to ensure compliance with those programs. §§1641(c)(1)(B), (d)(2)(A). Finally, although tribes might have greater ability to expand their operations because they, unlike IHS, are not prohibited from using Medicare and Medicaid proceeds to construct new facilities, to the extent that a tribe expands its programs beyond the “Federal program,” IHS would not have to pay contract support costs for the tribe’s new programs. Pp. 15–16.

 (d) A contrary reading of the statute would impose a penalty on tribes for opting in favor of greater self-determination. Contract support costs are necessary to prevent a funding gap between tribes and IHS. If IHS does not cover those costs to support a tribe’s expenditure of program income, the tribe would have to divert some program income to pay such costs, or it would have to pay them out of its own pocket. Either way, it would face a penalty for pursuing self-determination, contrary to the policy underlying ISDA. Pp. 17–18.

No. 23–250, 53 F. 4th 1236; and No. 23–253, 61 F. 4th 810, affirmed.

 Roberts, C. J., delivered the opinion of the Court, in which Sotomayor, Kagan, Gorsuch, and Jackson, JJ., joined. Kavanaugh, J., filed a dissenting opinion, in which Thomas, Alito, and Barrett, JJ., joined.

Notes
¹Together with No. 23–253, Becerra v. Northern Arapaho Tribe, on certiorari to the United States Court of Appeals for the Tenth Circuit.