The Texas Supreme Court in the case of In re. J.Y.O., 709 S.W.3d 485 (Tex. 2024) held that a discretionary bonus paid to a spouse after divorce for work performed during marriage is community property. In divorces where a spouse usually is paid a bonus for work done during the prior year, the bonus should be divided or awarded in the divorce decree. If the divorce is finalized on October 1, for example, the decree could award the wife half of 75% of the husband’s bonus which he is paid the next February, with the husband being named a constructive trustee of the funds and ordered to notify the wife within three days of his receipt of the bonus.