Cal. Code Regs. tit. 18, § 15103.1
(a) Real Property.
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.
(b) Tangible Personal Property.
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.
(c) Intangible Personal Property.
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.