courts, noted that stock options are a form of deferred compensation that has been earned by the employee. 564 Pa. 586, 769 A.2d 1165, 1168 (2001). In Fisher, the husband received several stock options from his employer during the marriage. Id. at 1167. These options would terminate even upon the husband’s death or disablement. Id. The court in Fisher reasoned that un-vested stock options are similar to pension benefits, in that both are awarded to the employee to induce that employee to remain in his or her present employment; otherwise, an employee’s compensation would arguably be higher. Id. The court, also relying upon the majority of other states, concluded that unvested stock options that were earned prior to the divorce must be considered marital a Cal.Rptr. 676, 685 (1984) (<HOLDING>); Salstrom v. Salstrom, 404 N.W.2d 848, 850
holding that unexercised stock options were not marital property holding that the trial court did not abuse its discretion in allocating the husbands unvested stock options as marital property holding that the trial court properly determined that unvested stock options have marital aspect holding that unvested stock options subject to the contingency of debtors future employment are property of the bankruptcy estate holding that unvested stock options are a form of compensation and constituted marital property that could be distributed through use of a constructive trust