(a) Except as provided in subsection (b) of this section, the Maryland estate tax does not apply to the transfer of personal property in an estate of a nonresident decedent, if, at the time of death, the decedent is a resident of a state or foreign country whose law, when the personal property is transferred:

(1) does not impose death taxes on the transfer of similar personal property of a resident of this State; or

(2) contains a reciprocal exemption from death taxes similar to the exemption allowed under this subsection.

(b) The exemption under subsection (a) of this section does not include a transfer of tangible personal property that has a taxable situs in this State.