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As far as I know, it can't be tucked under the subframe (like way under the undertail). Other than that, I'm sure it just has to be visible/legible at a certain angle.
"technically" , as in by-the-book, a vertical plate isn't legal. Most cops don't care though, as long as it's plainly visible from the rear of the bike, and has a light on it, you're generally ok.
edit- I dont know the difference between it and in.
what i was going to originally post but decided against it cause of placement ideas
such as the squid way of a tattoo on the lower back or other places