Correct, constructive may not have occurred yet. However, in the case of Bittrex/Trezor, it sounded as though the Bitcoin Gold is credited to the taxpayer, however just not as functional (for Trezor you would have to re-upload the "seed" to another third party wallet). So constructive receipt may have occurred, but an economic benefit is called into question.

Constructive receipt is an important consideration so I added above, it's great to have a second set of eyes, thank you!