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Chapter 1. Inheritance Tax›Article 5.2. Intangibles Exemption

§ 13851. Nature, Scope and Amount.

California Code of Regulations, Title 18 — Division 2.5. State Controller · 2026 edition · updated 2026-10-05 · California

Source: https://govt.westlaw.com/calregs/Document/IE76957334C8311EC89E5000D3A7C4BC3?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Default)

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:

(a) Did not impose such a tax in respect to intangible personal property of residents of this State; or

(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.

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▸Contents — California Code of Regulations, Title 18 — Division 2.5. State Controller

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