Constructive Receipt v. Economic Benefit

[Guest kp]

Does anyone have a good explanation (with examples) of the distinction between constructive receipt and economic benefit?

[Guest bswift]

Hey kp, I have a decent speech outline on the topic and can tell you that its the difference between Section 83 (transfer of property) and section 451 (taxable year of inclusion). See Treas. Reg. Sec. 1.451-2(a). If you like, just E-mail me and I might be able to help re the outline.