I respectfully dissent. A marital community has a contractual entitlement to all benefits earned by a spouse during the marriage under *189terms and conditions of employment then in effect. In my view, however, a dissolved community has no stake, by contract or otherwise, in any “enhancement” of benefits that was first offered after the marital separation and was not in effect during the marriage. This should particularly be the rule when the enhanced benefits are a new employer “subsidy” provided for the purpose of inducing a voluntary termination of employment, the future earnings and pension rights from which would themselves have been the employee spouse’s separate property.
While this couple was married, the marital community, through the employed husband, contributed its services in return for a contractual right to compensation including (1) the husband’s current salary during that period, and (2) the conditional future right to collect retirement pension benefits, insofar as attributable to work performed during the marriage, under the terms of the company retirement plan as in effect when the work was performed. That plan would apparently have allowed the husband to choose either “normal” retirement at age 65, or “early” retirement between ages 55 and 65 subject to a reduced monthly benefit payment. The monthly payment for “early” retirement would be lower for two reasons. First, by selecting early retirement, the husband would cease earning service credits and salary increases relevant to computation of a final pension. Second, he would sustain an actuarial adjustment in the monthly benefit, reflecting the longer life expectancy over which the pension earned would be paid.
Years after the marital community ceased to exist, at a time when the employee’s salary and service credits were his alone, the employer, in an effort to eliminate positions, sought to induce his voluntary early retirement by offering him an increase in the reduced monthly pension benefits to which early retirement would otherwise entitle him. The increase was accomplished by granting years of putative future service credit and waiving the actuarial adjustment for early retirement.
The erstwhile community performed not one minute of work under an employment contract that included these “enhanced” benefits, or in expectation thereof. Instead, the community offered its services under the terms and conditions of compensation then in effect, and passed from existence with that understanding. The new benefits, announced long after dissolution of the marriage, sought to encourage and compensate the divorced husband’s early withdrawal from his own employment, the future earnings and pension credits from which would have accrued solely to him.
Certainly the community, though long extinct, is entitled to share pro rata in the pension payments for which the husband became eligible at his *190retirement under the plan in effect during the mariage. When contributing its time, effort, and skill to the husband’s work during the marriage, the community contracted for, earned, and expected no less. (See, e.g., In re Marriage of Brown (1976) 15 Cal.3d 838, 844 [126 Cal.Rptr. 633, 544 P.2d 561, 94 A.L.R.3d 164] {Brown) [“community owns all pension rights attributable to employment during the marriage”].)
Yet the majority go further. They reason that once an employee “has accrued a right to retirement benefits, at least in part, during marriage before separation, the retirement benefits themselves are stamped a community asset from then on.” (Maj. opn., ante, at p. 183.) Hence, they conclude, when a pension’s terms change in the employee’s favor after the marriage has ended, as a means of inducing the employee to forgo his own future work earnings and retire early, the ancient community retroactively gains a full proportionate share of the enhancement. The majority refuse even to concede the now-unmarried employee the full benefit of years of future age and service credit attributed to him under the “enhanced” voluntary retirement plan, though by actually working during the same future period, the husband would without doubt have accrued those same years of age and service for his sole account.
I cannot accept such a holding. The majority’s result is at odds with the fundamental premise that community property is limited to that acquired during the marriage (Fam. Code, § 760), while assets earned or accumulated by the marital parties at any time after their separation are their separate property {id., §§ 771, 772).
In support of their views, the majority advance two related premises. First, the majority imply, by contributing labor toward a spouse’s pension, the community makes an “investment” in, and thus earns and acquires a pro rata “property” right to, the “stream of income” for which the employee will finally be eligible, as determined by all intervening events, both good and bad, that precede the employee’s retirement. Second, the majority suggest, the community has earned an interest in any final pension, including post-marital “enhancements” thereof, insofar as it contributed eligibility credit toward the final pension. These theorems, in the extreme form the majority apply them, are supported neither by our prior decisions nor by sound logic.
Thus, prior to Brown, supra, 15 Cal.3d 838, California adhered to the rule that pension interests which had not “vested” (i.e., which remained subject to forfeiture through termination of employment) at the time of dissolution *191remained a mere “expectancy,” and were thus not a divisible item of community property. (E.g., In re Marriage of Fithian (1974) 10 Cal.3d 592, 596 [111 Cal.Rptr. 369, 517 P.2d 449]; French v. French (1941) 17 Cal.2d 775, 778 [112 P.2d 235, 134 A.L.R. 366].) Our seminal Brown decision abrogated this doctrine, concluding that accrued rights in a pension arising from the explicit terms and conditions of employment could constitute divisible community property even if such rights were not yet “vested” at the time of dissolution. Our opinion emphasized that the right to earn a pension is contractual in nature, a form of deferred compensation which “derive[s] from the terms of the employment contract.” {Brown, supra, 15 Cal.3d 838, 845, italics added.)
We observed that the constitutional prohibition against impairment of contracts had been held to preclude a public employer from unilaterally withdrawing even nonvested pension rights which have already been earned by the employee’s performance of work. {Brown, supra, 15 Cal.3d 838, 845-846.) A parallel rule had arisen in the private sector, we noted, such that an employer could not repudiate even nonvested pension rights “once the employee performed services in reliance upon the promised pension” {id., at p. 846, italics added); instead, the employee “could enforce his right . . . either under traditional contract principles of offer, acceptance and consideration or under the doctrine of promissory estoppel. [Citation.]” {Ibid., italics added.)
Thus, we reasoned, this interest is a chose in action rather than a mere “expectancy” or hope of future beneficence as to which no enforceable right exists. Insofar as the community contributed its time, labor, and effort toward the accumulation of such contractual rights, we concluded, it must share pro rata in their value. {Brown, supra, 15 Cal.3d 838, 844-847.)
“Brown’s message is very simple. An employment benefit, whether or not vested, is community property to the extent a right to it accrues during marriage.” {In re Marriage of Frahm (1996) 45 Cal.App.4th 536, 544 [53 Cal.Rptr.2d 31] {Frahm), italics added.)
No such accrual occurred here. When the instant community performed its work, there was no contractual right or interest, “vested” or “nonvested,” *192“mature” or “immature,”1 nor even a bare “expectancy,” in the “enhanced” benefits over which the wife now seeks to assert a community interest. By performing its services, the community did not “accept” the employer’s “offer” of “enhanced” pension terms, nor did the community contribute its labor in “reliance” on a “promise” of such terms. The employer acquired no legal or equitable obligation, by virtue of the community’s efforts, to provide such “enhanced” benefits. They simply were not in the contemplation of the parties when the community effort was expended. Hence, nothing in the reasoning or holding of Brown supports the view that this community acquired rights in pension “enhancements” offered by the husband’s employer only after the community had dissolved.2
Until today, no subsequent decision of this court had expanded Brown’s holding to recognize a community interest in employment benefits first afforded after the community had dissolved. In In re Marriage of Skaden (1977) 19 Cal.3d 679 [139 Cal.Rptr. 615, 566 P.2d 249], we concluded, for reasons similar to those set forth in Brown, that the dissolved community had an interest in “severance payments,” the rights to which were spelled out in the initial employment contract under which the community had contributed its labor. In re Marriage of Stenquist (1978) 21 Cal.3d 779 [148 Cal.Rptr. 9, 582 P.2d 96] held that an employee cannot entirely defeat an ex-spouse’s community pension interest by electing a separate-property disability *193pension in lieu of a normal longevity pension for which the employee is also eligible. In re Marriage of Gillmore (1981) 29 Cal.3d 418 [174 Cal.Rptr. 493, 629 P.2d 1] (Gillmore) and In re Marriage of Cornejo (1996) 13 Cal.4th 381 [53 Cal.Rptr.2d 81, 916 P.2d 476] simply explained that if an ex-spouse has not previously been “cashed out” of his or her community property interest in the employee’s pension, an employee who chooses to continue working after eligibility for retirement has occurred may nonetheless be required to start paying the ex-spouse the latter’s pension share.3
Neither of the majority’s reasons for now deeming postmarital pension “enhancements” to be community property is persuasive. The majority first advance the notion that even if “enhanced” pension benefits were first offered only after the marriage was dissolved, the community nonetheless earned and thus “acquired” rights thereto during the marriage insofar as community efforts account for a portion of the employment (including age and service credit eligibility requirements) which “underlies” the pension as a whole. The premise appears to be that when the community contributes, during any period, its time, effort, and skill to a particular employment, it then and there earns and acquires rights to a pro rata share of any pension the employee spouse ultimately receives, including amounts that stem from postmarital improvements to the pension plan.
For a simple reason, however, I cannot agree. As indicated above, a community provides its time, effort, and skill on the basis of the terms of compensation then in effect. Those terms include the conditional right to a future pension under the existing pension rules, but do not include new and *194additional pension benefits conferred on the employed spouse only after the marriage has dissolved. While it existed and contributed its labor, the community earned and accrued no interest, expectancy, entitlement, or enforceable right in such changes.4 By definition, such postmarital benefits cannot be “property . . . acquired by a married person during the marriage” (Fam. Code, § 760, italics added), and thus community property, but instead must constitute postseparation “earning[s]” or “accumuIation[s]” that inure to the sole benefit of the employee (id., §§ 771, 772). (Frahm, supra, 45 Cal.App.4th 536, 544; see In re Marriage of Nelson (1986) 177 Cal.App.3d 150, 156-157 [222 Cal.Rptr. 790] [stock options and bonus conferred only after separation are employee’s separate property]; also cf. In re Marriage of Walker (1989) 216 Cal.App.3d 644, 651 [265 Cal.Rptr. 32] [“The community has an interest in employment benefits conferred during marriage.”].)5
The majority insist their rule is necessary to treat the community fairly because, having borne the “risk” of intervening contingencies that might reduce or eliminate the ultimate pension amount, the community is entitled to the potential “reward” of beneficial contingencies, including postmarriage improvements to the plan. But this reasoning is flawed, because the “risks” *195the community faces are not commensurate with the “reward” the majority confers.
When a married employee performs labor and accrues rights under the terms of an existing plan to pay future pension benefits, the community faces, and can assess as it continues to work, the “risk” that the contingencies and conditions set forth in the plan itself will not come to pass in the most advantageous way. As the community works, it well understands by reference to the plan already in existence that the pension amount ultimately due, and the community’s share thereof, may be eliminated or reduced insofar as the employee dies before retirement, retires early, changes jobs, is discharged from employment, or fails to attain the hoped-for level of final compensation. By the same token, the community should reap the “reward” when the pension rules under which the community’s labor was contributed turn out to produce a favorable result.
But an improvement in the plan that occurs only after the marriage has ended is not the mere favorable resolution of a contingency or condition the community assumed when performing its services. Instead, such an enhancement is a new and unforeseeable development, one unrelated to the assumptions under which the community supplied its labor. Such a postmarital improvement constitutes no legitimate “reward” for the “risks” the community faced when earlier deciding whether to contribute its time, effort, and skill. Considerations of fairness do not suggest that the community, long interred, may rise from its ashes to claim a retroactive stake in such a benefit.6 On the contrary, by retaining its rights under any and all pension terms in existence when community contributions were made, the community obtains the full benefit of its bargain.
*196Even if there are circumstances in which a former community might properly participate in postmarital pension changes, this is not such a case. The “enhanced” benefits offered the husband in this case were not part of a companywide retroactive upgrade of the terms and conditions of employment. On the contrary, they were part of a limited program, targeted at a particular category of employees, and based upon specific personnel considerations applicable to that group at the time the program was announced. They were not intended as a reward for an employee’s past work, nor did they reflect the true value of pension credits earned by the employee’s actual service (including community service). On the contrary, they represented a new subsidy by the employer, offered for the sole purpose of inducing the targeted employees including husband, who was now unmarried and working for his sole account, to forgo future employment and the earnings associated therewith.
As the majority disclose, the program, announced in March 1993, was labeled a “Voluntary Retirement Incentive.” (Italics added.) It was offered only to employees who, as of December 31, 1992, were 50 or older with at least 15 years of credited service, and who, as of February 17, 1993, worked in specified departments of the company. Those eligible were promised “valuable financial incentives” (italics added), “available only if you elect to retire through the program” (italics added), which would “make retirement an even more attractive option.” The informational brochure described the program as a “management tool” to “reduc[e] costs” by “bring[ing] our workforce in line with the needs of our changing business.” “This VRI,” the brochure explained, “is developed to suit the needs of a particular situation!,,] ... is targeted to areas where reduction [in the workforce] is most needed[,] and strikes a balance between the stated objectives of cost reduction and fair treatment for our employees.” As already recounted (see fn. 5, ante), the proffered “incentives” included, for the first time, the rights (1) to retire up to nine months before the usual minimum early retirement date, (2) to receive fictional years of service credit, and (3) to receive a monthly benefit calculated as though retirement was occurring at age sixty-five, the “normal” retirement age.
Manifestly, the increased monthly retirement benefit offered in return for participation in the VRI program was intended as consideration for the *197employee’s postmarital agreement to retire early, and as a partial replacement of the future compensation, both in monthly salary and in continuing accrual of pension rights, that the employee would thereby give up. Pension rights under the VRI option stemmed from a separate contract between the employee and the employer, offered and accepted after the marriage ended for reasons unrelated to the former community’s efforts. This contract was intended to govern future, not past, relations between employer and employee. It was subsidized anew by the employer rather than reflecting the value of credits previously accumulated. Accordingly, it was independent of any community interest.7
In concluding otherwise, the majority merely restate the same unpersuasive theories discussed above. The dispositive point, the majority insist, is that the early retirement inducement was provided through the pension, a *198form of benefit that “derive[s]” from past employment and depends in part on effort, years of chronological age, and service longevity contributed by the community. By earning rights in the pension itself, the majority conclude, the community thus also earned and acquired a right in any terms under which the pension was ultimately payable, even terms first offered after the marriage ended in order to induce the employee to retire early.
As I have already demonstrated, however, the majority’s expansive notion of community pension rights does not comport with the contract and community property principles set forth in Brown. Moreover, for reasons the majority themselves suggest, the community or separate nature of a post-marital early retirement inducement should not depend on the precise means by which an employer has chosen to provide the inducement. The employer acts for its own business convenience, and is not primarily motivated by a concern for the community property consequences of its action. Here it is clear that by promising a new benefit to designated employees who agreed to retire early, the employer sought to encourage such early retirements and to provide the workers who chose that option at least partial compensation for their resulting loss of future earnings. That the employer elected to accomplish these goals through “enhanced” pension benefits, rather than some other means such as stock options or lump-sum severance payments, should not affect how the inducement is treated under the laws of community property.
Finally, the majority’s holding will be a negative influence on the overall disposition of dissolution proceedings. Wherever possible, the parties to a marital dissolution should be encouraged to divide their property promptly and get on with their lives. (See, e.g., Phillipson v. Board of Administration (1970) 3 Cal.3d 32, 46 [89 Cal.Rptr. 61, 473 P.2d 765].) However, the rule announced today will weigh against a nonemployee spouse’s decision to “cash out” of the employee’s pension at the time of dissolution. If, and only if, division of the pension is left open until the employee retires—often years after the marriage has ended—the ex-spouse may gain a share of favorable pension terms later offered to the employee as an inducement to retire early. There appears no persuasive ground to impose this further incentive for delay in the final division of marital property.
For all these reasons, I conclude that the instant community is entitled to share pro rata, by application of the “time rule,” in the $2,350.39 monthly benefit the husband would receive for early retirement at age 55 under the previously existing pension plan, but has no interest in the additional $708.91 monthly amount attributable to the VRI “enhancement.” I would *199therefore reverse the judgment of the Court of Appeal. I would remand the cause to that court with directions to order further trial court proceedings consistent with the views expressed in this opinion.
Chin, J., concurred.
As Brown explained, in discussions of community property interests in pensions, a pension right is deemed “mature” when a present right to payment of benefits has arisen, as on eligibility for retirement. {Brown, supra, 15 Cal.3d 838, 842.)
Taken out of context, Brown’s assertions that pension rights “derive” from, or are “attributable to” employment, and that pension benefits are a form of “deferred compensation," may have contributed to subsequent misunderstanding in the Courts of Appeal about a former community’s rights in employment benefits offered to or received by the employee after the marriage has ended. Since Brown was decided, a number of lower court decisions, addressing a wide range of situations, have assumed that employment-related benefits are community property to the extent they are “attributable” to prior community effort or appear intended as “deferred compensation” for past work rather than compensation for loss of future earnings, even though the payment or benefit was not part of the terms and conditions of employment when the community contributed its labor. (See, e.g., In re Marriage of Gram (1994) 25 Cal.App.4th 859, 862-867 [30 Cal.Rptr.2d 792] {Gram), In re Marriage, of Lawson (1989) 208 Cal.App.3d 446, 452 [256 Cal.Rptr. 283]; In re Marriage of Horn (1986) 181 Cal.App.3d 540, 547-548 [226 Cal.Rptr. 666]; Downer v. Bramet (1984) 152 Cal.App.3d 837, 843 [199 Cal.Rptr. 830]; In re Marriage of Wright (1983) 140 Cal.App.3d 342, 344-345 [189 Cal.Rptr. 336]; In re Marriage of Flockhart (1981) 119 Cal.App.3d 240, 242-243 [173 Cal.Rptr. 818]; also cf. In re Marriage of Gowan (1997) 54 Cal.App.4th 80, 87-91 [62 Cal.Rptr.2d 453]; In re Marriage of Melton (1994) 28 Cal.App.4th 931, 938-939 [33 Cal.Rptr.2d 761].) However, as indicated above, Brown merely acknowledged the community’s interest in enforceable contractual rights accrued by reason of the terms and conditions under which the community’s employment actually took place. Neither Brown nor our subsequent cases (see text discussion, post) provide any basis for a conclusion that postmarital benefits are community property.
In Gillmore, we observed that a nonemployee spouse who elects to “cash out” of the employee’s pension at the time of dissolution thereby forfeits the right to share in the “increased [future] value” of the pension benefits. However, we made clear that any such “increased value” was that which “ ‘might accrue due to increased age, longer service and a higher salary.’ ” (Gillmore, supra, 29 Cal.3d 418, 428, fn. 9, quoting In re Marriage of Luciano (1980) 104 Cal.App.3d 956, 961 [164 Cal.Rptr. 93], italics added.) This passage does not imply that the nonemployee spouse, by deferring his or her pension share until the employee becomes eligible to retire, thereby acquires an interest in intervening changes in the pension formula.
In establishing the general principle that an employee cannot manipulate his pension rights to the prejudice of the former community, our decisions have suggested that the employee can agree to a postmarital “modification” of the pension terms so long as the former community’s interest in the pension is not thereby defeated or substantially impaired. (E.g., Gillmore, supra, 29 Cal.3d 418, 425-426; Brown, supra, 15 Cal.3d 838, 849, & fn. 11.) But by placing limits on the employee’s contractual right to undermine the pension already earned by the former community, we did not intimate that more favorable pension terms first offered to the employee after the marriage has ended must inure to the benefit of the former community, which did not supply its labor on those terms.
Thus, it seems clear that if the wife in this case had elected at the time of dissolution to receive the present value of her pension rights as a lump sum, no value could have been assigned to the possibility of future beneficial changes in the terms of the pension plan. (See fn. 3, ante.)
Even if I agreed that postmarital pension “enhancements” should inure to the former community’s benefit insofar as the community contributed years of age and service bearing on the employee’s entitlements, I would dispute the majority’s application of that principle to the facts before us. Besides allowing retirement up to nine months before the usual minimum retirement age of fifty-five, the instant employer’s “Voluntary Retirement Incentive” (VRI) plan “enhanced” the employee’s pension in two ways: first, by adding three years of putative or “fictive” service credit, and second, by waiving the actuarial reduction for retirement at an early age. The majority accord the community a full pro rata share of both “enhancements” by direct application of the “time rule”; under their formula, the community’s years of service credit are divided by the husband’s total actual years of service credit to determine the community’s percentage share of the total “enhanced” monthly pension amount. (Community years of service (17.39) divided by husband’s actual total years of service (32.67) equals .5323 or 53.23 percent.) However, neither of the “enhancers” in the VRI plan operates or depends, by its terms, upon years of age or service credit previously contributed by the community. Instead, the “fictive” additional years of service credit serve as a replacement for credits the husband, but for the early retirement, would have earned for his own account in the future. (See Gram, supra, 25 Cal.App.4th 859, 867 [concluding that “fictive” years of service credit in postmarital early retirement plan must be added to husband’s actual years of credit before “time rule” is applied].) The actuarial waiver also seems simply a means of redressing a disadvantage caused by the early retirement itself, and is the equivalent of adding “fictive” years of employee age which were not contributed by the community. (Cf. Gram, supra, at p. 861.) No persuasive reason appears why “enhancing” features of this kind should simply be allocated pro rata to the community.
The majority imply that the community may indeed face the “risk” of disadvantageous changes in a pension plan which occur after dissolution of the marriage. But that “risk” is sharply limited by the principles of vested contractual rights. In essence, these provide that pension rights already earned cannot be eliminated or materially impaired, either by the employer unilaterally (see, e.g., Betts v. Board of Administration (1978) 21 Cal.3d 859, 863-864 [148 Cal.Rptr. 158, 582 P.2d 614]; Brown, supra, 15 Cal.3d 838, 846, & fn. 7; Hunter v. Sparling (1948) 87 Cal.App.2d 711, 725 [197 P.2d 807]), or by the employee’s agreement (see fn. 3, ante). Indeed, while the instant employer reserved the right to amend the VRI plan as changing circumstances might require, it acknowledged in the VRI brochure that “no amendment of a plan may deprive a person of a vested interest in the Retirement Plan and Savings Fund Plan benefits.”
The majority also propose that by supplying labor under the terms of a pension plan which expressly permits future modification of nonvested rights, as such plans typically do, a community thereby understands it is acquiring an interest in whatever increased “stream” of retirement income such future modifications may produce. (Maj. opn., ante, p. 178, fn. 1.) The premise is unpersuasive. By reserving the freedom to modify the pension’s terms in the future, except as to vested rights, the employer merely warns that it can, and may, reduce or eliminate retirement benefits attributable to work thereafter performed, or as to which no *196contractual right has otherwise yet arisen. Such a warning does not give the community a right to share retroactively in beneficial pension changes that occur only after the community has dissolved. Moreover, the increased benefits at issue in this case did not stem from a routine pension “modification” the community might have anticipated at the time it contributed its time, effort, and skill. Instead, they arose from a later special arrangement between the employer and particular employees, outside the usual pension program, as a means to induce and compensate early retirements desired by the employer. (See discussion, post.)
Even when incorporated into an existing pension plan, such an “enhancement” is necessarily a new “subsidy,” just as a lump-sum “severance payment" would be, to the extent it exceeds the present value of pension credits accumulated and funded under the existing plan. We recently acknowledged this principle in another context. In In re Marriage of Oddino (1997) 16 Cal.4th 67 [65 Cal.Rptr.2d 566, 939 P.2d 1266] {Oddino), the husband’s pension plan (Plan) allowed early retirement between ages 55 and 65, and also utilized the “Rule of 75,” under which an eligible employee whose years of age and service credit totaled 75 or more could retire early without suffering a consequent actuarial reduction in monthly benefits. When the husband reached age 55, he was qualified for early retirement under the Rule of 75 but chose to continue working. The ex-wife sought to require the Plan to begin immediate payments of her pension share, calculated as though the husband had retired on his 55th birthday under the Rule of 75. The federal Employee Retirement Income Security Act of 1974 (ERISA) provides that a private pension plan need make direct payments to persons other than the covered employee only if directed to do so by a state court’s “qualified domestic relations order” (QDRO). A QDRO may be used to enforce an ex-spouse’s state-law right to immediate pension payments when the employee, though eligible to retire, has elected to postpone retirement. In such a case, however, payments under the QDRO must be calculated on the basis of the “present value of benefits actually accrued and not taking into account. . . any employer subsidy for early retirement.” (29 U.S.C. § 1056(d)(3)(E)(i)(II), italics added.) We upheld the Plan’s contention that when calculating payments to the ex-spouse under her QDRO, the Plan must apply the usual actuarial reduction for early retirement, because waiver of that reduction under the Rule of 75 is an early retirement “subsidy.” {Oddino, supra, 16 Cal.4th at pp. 82-88.) Among other things, we noted that “employers not infrequently subsidize employees’ early retirement as an incentive for specified groups of employees to leave the employer’s work force voluntarily, so as to reduce its wage burden or ‘avoid litigation that might result from laying off an employee.’ [Citation.] Such subsidized early retirement programs are a ‘quid pro quo between the plan sponsor and the participant.’ [Citation.]” {Id. at p. 88, italics added.)
The issues and policies under consideration in Oddino are not directly dispositive here. However, Oddino’% analysis supports the principle that pension amounts not actually earned by employment, but offered after the employee’s marriage has ended as a subsidy for early retirement, are a matter between the employee and employer alone, and are not “attributable” to community effort so as to transmute them into community property. Indeed, the “fictive” service and age credits provided by the instant VRI plan closely resemble the “subsidized” pension enhancements at issue in Oddino.