What is meant by constructive receipt?
Constructive receipt is the doctrine that taxes income before it is actually received. It is explained in Treasury Regulations § 1.451-2(a): “Income although not actually reduced to a taxpayer’s possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received in the taxpayer’s control of its receipt is subject to substantial limitations or restrictions.
