Cal. Code Regs. tit. 18, § 13851
(b) Had a reciprocity provision in its law exempting from its tax the intangibles of nonresidents of other jurisdictions whose laws, in turn, contain a similar exemption.
It will be noted that intangible personal property belonging to a nonresident transferor residing in the United States is not subject to the Inheritance Tax Law.
Note: Reference:Section 13851, Revenue and Taxation Code.
A transfer of intangible personal property subject to the Inheritance Tax Law by a nonresident transferor (see Section 13303.2(d)), is exempt from the Inheritance Tax Law in the amount of the property transferred 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: