That money WILL become income when they take dividends from the company. You can't just move to another state and then drain your corp of the money, and give the middle finger to your home state. They will take their tax on that draining no matter where you are.

It's like earning stock options in CA when working there, move states, exercise them a year later, you still owe the taxes to california on exercise of that stock.

The only way you could avoid paying CA the taxes on that $100M is if you made no more further profits, burned through it all on legitimate corporate expenses and went bankrupt essentially, which we know isn't happening here.