Cal. Code Regs. tit. 18 § 13646
An inter vivos transfer conforming to Revenue and Taxation Code Section 13641, whether in trust or otherwise, subject to a power reserved in the transferor to revoke, terminate, alter, amend, revise, or change the interest of the beneficiary, constitutes a transfer intended to take effect in possession or enjoyment at or after the death of the transferor, and is subject to the Inheritance Tax Law.
A transfer in trust of intangible personal property located outside this State by a nonresident trustor to a nonresident trustee for the benefit of a third person, with a power reserved in the trustor to revoke, terminate, alter, amend, revise, or change the interest of the beneficiary, is subject to the Inheritance Tax Law if the trustor subsequently dies a resident of California without having terminated, relinquished, or surrendered the power; or subsequently becomes a resident of California and then terminates, relinquishes, or surrenders the power in contemplation of death.
A power to revoke, terminate, alter, amend, revise, or change the interest of a beneficiary includes a power exercisable either by the transferor alone or by the transferor and any other person not having a substantial adverse interest in the property transferred.
NOTE: Reference: Section 13646, Revenue and Taxation Code.
Cal. Code Regs. Tit. 18, § 13646