It seems reasonable that a argument can be made that property exist in one of those places rather than none. Maybe the Federal government should simple dictate where that is and then let local government handle the actually taxation.
The USA is one of only 3 countries to tax you no matter where you live. Which is really painful for Americans not living in the USA. They need to fix this...
The rest of the world taxes you as part of a territorial system, ie, where you live and have tax residence.
Otherwise the Gold on the face of the Reserve Bank of Australia balance sheet would belong to England.
I very much doubt anybody would suggest that England can tax the Gold of Australia any more. We'd never hear the last of it from the Aussies for starters.
Purity of tax theory is what ended up as Poll Tax riots in the UK. Eventually local taxation reverted to property as it tends to once pragmatism and reality reasserts itself.
California could get what it needs using a volumetric hut tax - unless it fancies going independent and setting up its own currency.