CRA references constructive receipt doctrine

In the course of a general discussion of the meaning of "received," CRA stated that Innovative Installation, 2009 TCC 580, found that "received" does not require "proceeds to pass directly to the taxpayer. The taxpayer can notionally or constructively receive it."

"Notional" is too broad.  The Federal Court of Appeal in the same case (2010 FCA 285) clarified that receipt includes indirect receipt, such as receipt by a mere conduit through which the funds flow.

Neal Armstrong.  Summary of 11 December 2013 T.I. 2013-0474161E5 under General Concepts – Payment and Receipt.