For all intents and purposes, Ohtani signed a 10 year, $461 million contract. That is how the MLB will treat the luxury tax situation. And that is the highest AAV of any MLB player.

$461 million value from Buster Olney

According to reports, that calculation works out to a $46MM average annual value and accompanying CBT hit for the Dodgers and Ohtani.

For CBT purposes, the expected average annual value on the contract is said to be about $46 million per year, people briefed on the terms said.