<!-- citation-library:start --> ## Citation reference MacDonald, Estate of (1990) 51 Cal.3d 262, 272 Cal.Rptr. 153, 794 P.2d 911 > [!info] Working notes > This is a personal working note. Citation details are for reference; opinion and current-status verification may still be pending. <!-- citation-library:end --> <!-- reviewed-cases-051-070:start --> ## Holding A transmutation writing must expressly show on its face that the property’s character or ownership is being changed; extrinsic evidence cannot supply the missing express declaration. The wife’s consent to another beneficiary for retirement accounts did not itself surrender her community ownership interest. > [!note] Scope and later law > No special terminology is indispensable, but the written expression must actually communicate the required change. Distinguish beneficiary consent from transfer of ownership. [[Codes & Rules/Family Code/Division 4 - Rights and Obligations During Marriage (§§ 700 – 1620)/Part 2 - Characterization of Marital Property (§§ 760 – 853)/Chapter 5 - Transmutation of Property (§§ 850 - 853)/Cal. Fam. Code § 852|Cal. Fam. Code § 852]] Original paraphrase based on the court opinion, checked October 25, 2026. Subsequent treatment has not been comprehensively checked. <!-- reviewed-cases-051-070:end -->