From my reading it is only equity that has monetary value that they are taxing; this has nothing to do with disgorging voting stock, it is merely intended to raise revenue.
Section 50303(c)(3)(C) says "For any interests that confer voting or other direct control rights, the percentage of the business entity owned by the taxpayer shall be presumed to be not less than the taxpayer's percentage of the overall voting or other direct control rights."
Section (D) says that the tax applies to earnable profit-percentage even if the prerequisites for said earn haven't occurred.
From https://oag.ca.gov/system/files/initiatives/pdfs/25-0024A1%2...
Section 50303(c)(3)(C) says "For any interests that confer voting or other direct control rights, the percentage of the business entity owned by the taxpayer shall be presumed to be not less than the taxpayer's percentage of the overall voting or other direct control rights."
Section (D) says that the tax applies to earnable profit-percentage even if the prerequisites for said earn haven't occurred.