Right now there is no way to determine whether a local notification is received when the app is in the foreground or in the background.
Here is a sample:
The passed-through event object is the same for both situations. However, with remote notification you have such ability: http://docs.appcelerator.com/titanium/latest/#!/api/PushNotificationData-property-inBackground
From Apple's docs, both remote and local notifications are handled similarly. You'll be able to tell whether a local notification is received in the foreground or the background if coding in Objective-C, but not in Titanium.
This is important since actions taken may need to be different accordingly. E.g. When in the foreground you might just want to display a notification, but not to interrupt what users are doing. When in the background, and users click the notification to launch/resume the app, you want to take the users directly to the action.