California Code of Regulations
Title 18 - Public Revenues
Division 2.5 - State Controller
Chapter 1 - Inheritance Tax
Article 1 - Definitions
Section 13303.2 - Property of Nonresident Transferors

(a) Real Property.

Real property in this State belonging to a nonresident transferor is subject to the Inheritance Tax Law.

(b) Tangible Personal Property.

Tangible personal property permanently in this State belonging to a nonresident transferor is subject to the Inheritance Tax Law.

(c) Intangible Personal Property Belonging to a Nonresident Residing in the United States.

Intangible personal property belonging to a nonresident transferor residing in the United States is not subject to the Inheritance Tax Law.

(d) Intangible Personal Property Belonging to Nonresident Residing Outside United States.

Stocks and bonds issued by a corporation organized under the laws of California or which has its principal place of business or does a major part of its business in California or of a federal corporation or national bank which has its principal place of business or does a major part of its business in California, whether the evidence thereof is kept within or without the State, and all other intangible personal property in California belonging to a nonresident transferor residing outside the United States except savings accounts in savings and loan associations operating under the authority of the Division of Savings and Loan or the Federal Home Loan Bank board and bank deposits, unless such deposits are used in connection with a business conducted or operated, in whole or in part, in California, are subject to the Inheritance Tax Law. However, Revenue and Taxation Code Section 13851 exempts such intangible personal property from the inheritance tax if the transferor at the time of his death was a resident of a foreign state or country which then imposed a legacy, succession, or death tax in respect to the intangibles of its own residents, but either: