California Revenue & Taxation Code
Cal. Rev. & Tax. Code § 17855
The term “unrealized receivables,” as defined by Section 751(c) of the Internal Revenue Code, shall not include any of the following:
(a)
Stock in certain foreign corporations, as described in Section 1248 of the Internal Revenue Code.
(b)
Oil, gas, or geothermal property, described in Section 1254 of the Internal Revenue Code.
Source: official text