Real property in this State belonging to a resident donor is subject to the Gift Tax Law. Real property outside the State belonging to a resident donor is not subject to the law.
Tangible personal property in this State belonging to a resident donor is subject to the Gift Tax Law. Tangible personal property permanently outside the State belonging to a resident donor is not subject to the law.
Intangible personal property, wherever situated, belonging to a resident donor is subject to the Gift Tax Law.
NOTE: Reference: Section 15103, Revenue and Taxation Code.
Cal. Code Regs. Tit. 18, § 15103.1