That's his point. Crazy situation.
His main
chiddush is that Yahoo's Alibaba stake is worth full sticker price since Alibaba can acquire it without incurring the tax liability. He's wrong because if Alibaba issues 384m new shares, they will dilute the current share basis since they won't be tied up.
Basically, Alibaba has an outstanding liability of 384m stock options at 15 cents on the dollar (the fact that the 15 cents aren't going to Ailbaba is only marginally relevant). He's claiming that 384m standard shares would have the same effect.