The law isn't based on where your corporation is formed. It's based on where you reside.
It's technically phrasing is something like "If the person who caused the sale to happen resides in the state of California, the customer of this person must pay an affiliate tax."
If it were that easy, it'd be no big deal at all.
No, I think he has a point. He isn't saying that owning a business located in Nevada will save you if you reside in Cali and you cause a sale to be made, but if the BUSINESS is the one who enabled the sale to take place and the business is not located in Cali, you should be good. In theory