Definition of Income
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Pulsifer Doctrine
Economic Benefit Doctrine
S.61(a)
Except as otherwise provided, gross income means all income from whatever source derived.
Common Law definition of gross income
GI includes an undeniable accession to wealth, clearly realized, over which a TP has complete dominion. (Glenshaw Glass)
Pulsifer rule
TP taxable on the econonimc benefits derived from the absolute right to income in the form of a fund which has been set aside for him in trust and is beyond the reach of the payer'sdebtors.