John Malone, the media industry’s most astute financial engineer, announced another one of his complex deals yesterday, this one involving the spinning off of subsidiary Liberty Entertainment and its simultaneous merger with DirecTV.

On the surface, the deal — an all-stock transaction that will give Malone a 24 percent voting stake in the new company — appears to make a takeover of DirecTV easier since it will now be a standalone company instead of an asset with Liberty Entertainment.

But in reality, it may make it more difficult.

“The tax-free nature of the deal for Liberty Entertainment would likely be compromised by any acquisition in the near term,” wrote Sanford Bernstein analyst Craig Moffett in a report.

Basically, the tax benefits accrued to Malone by the deal would likely be nullified if DirecTV was acquired within the next two years. It’s well known that Malone hates the idea of paying taxes even more than he loves doing deals, so he’s not likely to risk having to hand cash over to Uncle Sam even if an offer for DirecTV emerges.

Rumors have circulated for years that AT&T or Verizon might make a run at acquiring DirecTV.

Terms of yesterday’s deal call for a unit of DirecTV to merge with Liberty Entertainment, which in addition to its stake in DirecTV also includes three regional sports networks and controlling stakes in the Game Show Network and FUN Technologies. As a result of the merger, DirecTV will become Liberty Entertainment’s parent company.

DirecTV also agreed to provide the new entity with a $650 million loan to help pay down its $2 billion debt load.

The move is designed to unlock the value of DirecTV, which Wall Street had heavily discounted because of its status as an asset within Liberty Entertainment. Liberty Entertainment’s stake in DirecTV was considered by traders to be worth more than the market capitalization of Liberty Entertainment itself.