Answer:
Anything that cannot be touched is considered intangible, so like electricity is intangible and does software is still intangible. To read further...
The trouble is personal property law - whether Roman law or common law - developed in an era when not only was software unknown or unimaginable, but when even intellectual property such as copyright was unknown. It is only in the last few centuries that the law has recognised that property can subsist in any intellectual assets at all (as distinguished from intangibles such as debts). This law has developed in a piecemeal way so that only some species of intellectual assets have the status of property. The law has yet to adequately catch up with other intangibles such as electricity and now software.
It is time to reform the law of personal property to accommodate computer software. The attempt to side step the personal property conundrum by categorising (at least some) software as a service has only led to legal confusion and undesirable international trade implications. The law now needs to recognise a tertium quid between things in possession and things in action.