Plan A, while fairly conventional, got shot down by the IRS.
http://www.bloombergview.com/articles/2015-09-09/yahoo-s-ali...
http://www.bloombergview.com/articles/2015-09-09/yahoo-s-ali...
So if the above is roughly accurate it's more like the loophole everybody used is closing and now they're going with a less desirable loophole.