§4.04 Postseparation Efforts

When a spouse applies skill, efforts, and industry to increase community assets after separation, you should apply the apportionment formula of Pereira or Van Camp in reverse [Marriage of Imperato (1975) 45 CA3d 432, 438–439], as follows:

• Apply the Pereira approach to allocate a fair return of the increase to the community property and the excess to the spouse's separate property; or
• Apply the Van Camp formula to determine the reasonable value of the spouse's services (less any draws or salary taken), allocate this additional sum, if any, to the spouse as his or her separate property, and allocate the balance of the increase to community property.