According to the doctrine of constructive receipt, when is income considered received for tax purposes?

The doctrine of constructive receipt addresses the timing of income recognition for tax purposes, specifically when income is considered to be received, even if it has not been physically collected. According to this doctrine, income is viewed as constructively received when it is made available to the taxpayer without substantial limitations or restrictions.

This means that as soon as the income is set aside and can be drawn upon by the employee, it is considered received for tax purposes. For instance, if an employer declares a bonus and that bonus is available for the employee to access, even if the employee hasn’t taken physical possession of the funds or transferred them into their bank account, the employee must recognize that income in the tax year it was made available.

In contrast, other scenarios such as depositing funds into a bank account or transferring them to the employee's name do not automatically trigger recognition of income unless they meet the constructive receipt criteria. Physically collecting income is relevant, but again, the timing focuses on whether the income was made available without substantial limitations. Thus, the correct understanding of constructive receipt emphasizes access and availability rather than physical possession.