How does constructive receipt apply to a promissory note bonus?

Constructive receipt applies when income is made available so the taxpayer can draw on it, even if the taxpayer does not physically receive it. But it does not apply when the taxpayer's control is subject to substantial limitations or restrictions.

A bonus note raises questions such as whether the employee could demand cash, sell the note, transfer it without approval, or lose the right by failing to meet future conditions. Those facts determine whether the taxpayer had current access to income or only a restricted future right.