Sochatsky v. The Queen, 2011 DTC 1065 [at at 346], 2011 TCC 41, 2012 TCC 65 -- summary under Payment & Receipt

The individual taxpayer was found to have received a bonus from a closely-held corporation in the year that the corporation declared the bonus rather than in the subsequent year of payment in light of the withholding and remittance of source deductions on the full amount of the bonus in the first year, the booking by by the corporation in that year of a loan back to it of the net bonus proceeds and the absence of any evidence that this was done without his knowledge or consent. Jorré J. also quoted (at para. 78) with apparent approval a statement of commentators that "when money is paid by an employer to a third party for the benefit of the taxpayer, the payment constituted constructive receipt in the hands of the taxpayer."