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And there is where some grey area exists.In state you can transfer without FFL. Across state lines you have to use FFL
I know of intrafamilial transfers where the parent/child brought the guns into CA and gifted them to their CA resident child/parent while in CA. This means the transfer occurred in CA and thus satisfied the transfer form requirements.
Now I cannot speak to the legality of non-residents bringing their personal off roster firearms into/out of CA while visiting, and gifting some and returning with the rest, but that's what happened in the cases I know of.