Burchill v. Canada, 2010 DTC 5096 [at at 6922], 2010 FCA 145 -- summary under Subparagraph 56(1)(a)(i)

The Court rejected the taxpayer's argument that the reference in s. 56(1)(a)(i) to pension benefits "received" referred to benefits "constructively received," and that taxpayer was consequently entitled to allocate portions of a lump sum pension payment to earlier taxation years. If that argument were correct, then there would have been no need to enact s. 110.2 (allowing a deduction for prior years' accruals) and s. 120.31 (dealing with "notional tax payable" in prior years).