This past offseason, the Yankees non-tendered outfielder Slade Heathcott only to bring him back on a minor league contract. Declining to tender Heathcott a contract was the only way to get him off the 40-man roster without exposing him to waivers. They were able to drop him from the 40-man roster, keep him off waivers, and bring him back to the organization.
That move is risky, of course. Non-tendering a player makes him a free agent, so any team could have swooped in to sign Heathcott. That’s a risk the Yankees were apparently willing to take.