Inherited IRAs not exempt from bankruptcy

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TIAX
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Inherited IRAs not exempt from bankruptcy

Post by TIAX » Thu Jun 12, 2014 11:58 am

Just thought fellow bogleheads may be interested in today's Supreme Court decision holding that Inherited IRAs are not excluded from the bankruptcy estate.

This is at least one reason a spouse should rollover an Inherited IRA into a Rollover IRA.

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Raymond
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Re: Inherited IRAs not exempt from bankruptcy

Post by Raymond » Thu Jun 12, 2014 12:15 pm

Thanks for the very interesting link.

I am curious - the amount in the inherited IRA was ~$300,000.

How much was spent in legal fees by the petitioners (Clark and his wife) to avoid having that amount included in the bankruptcy estate?

[Edit]

Just to clarify:

Looking at IRS Publication 590 "Traditional IRAs", a beneficiary can rollover an inherited traditional IRA *from a deceased spouse*, but not one from a non-spouse.

Mrs. Clark inherited the traditional IRA from her deceased mother, so she could not have rolled it into her own IRA.
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TIAX
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Re: Inherited IRAs not exempt from bankruptcy

Post by TIAX » Thu Jun 12, 2014 12:40 pm

Raymond wrote:Thanks for the very interesting link.

I am curious - the amount in the inherited IRA was ~$300,000.

How much was spent in legal fees by the petitioners (Clark and his wife) to avoid having that amount included in the bankruptcy estate?
That's a good point. Perhaps the litigation was financed by groups who had an interest in the outcome of the case.

Here are the briefs in case people are interested in the arguments.

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Re: Inherited IRAs not exempt from bankruptcy

Post by Tanelorn » Thu Jun 12, 2014 12:47 pm

Raymond wrote:Mrs. Clark inherited the traditional IRA from her deceased mother, so she could not have rolled it into her own IRA.
Mrs. Heffron's estate planning failed to include marry her daughter in one of the more open-minded states in order to allow the spousal rollover and its associated bankruptcy protection. Worth keeping in mind.

Edit: fixed the names.
Last edited by Tanelorn on Thu Jun 12, 2014 1:28 pm, edited 1 time in total.

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Re: Inherited IRAs not exempt from bankruptcy

Post by TIAX » Thu Jun 12, 2014 12:59 pm

Tanelorn wrote:
Raymond wrote:Mrs. Clark inherited the traditional IRA from her deceased mother, so she could not have rolled it into her own IRA.
Mrs. Clark's estate planning failed to include marry her daughter in one of the more open-minded states in order to allow the spousal rollover and its associated bankruptcy protection. Worth keeping in mind.
That wouldn't work of course but the daughter could have divorced the husband and had him marry the mother :happy. Probably too much trouble for 300k.

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Raymond
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Re: Inherited IRAs not exempt from bankruptcy

Post by Raymond » Thu Jun 12, 2014 1:08 pm

Tanelorn wrote:
Raymond wrote:Mrs. Clark inherited the traditional IRA from her deceased mother, so she could not have rolled it into her own IRA.
Mrs. Clark's estate planning failed to include marry her daughter in one of the more open-minded states in order to allow the spousal rollover and its associated bankruptcy protection. Worth keeping in mind.
:confused

Mrs. Clark's mother was named Ruth Heffron.

Did you read the decision? I will admit it is a long read.

I guess you are being facetious about Mrs. Heffron marrying her own daughter :P

IANAL, but I am pretty sure that even "more open-minded states" do not permit parents to marry their biological children.
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Re: Inherited IRAs not exempt from bankruptcy

Post by bsteiner » Thu Jun 12, 2014 1:43 pm

The IRA owner could have left the IRA (and her other assets) to her daughter in trust rather than outright. That would have protected her inheritance from her creditors and spouses, and also kept it out of her estate for estate tax purposes.

Here is the opinion: http://www.supremecourt.gov/opinions/13 ... 9_mjn0.pdf .

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Re: Inherited IRAs not exempt from bankruptcy

Post by manwithnoname » Thu Jun 12, 2014 4:49 pm

All assets held in a retirement plan subject to ERISA are protected from claims of bankruptcy creditors, including IRA assets that are rolled over to the retirement plan. If IRA assets are rolled over to an employer plan there is no need to set up a trust. However inherited IRA assets cannot be rolled over.

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Re: Inherited IRAs not exempt from bankruptcy

Post by letsgobobby » Thu Jun 12, 2014 5:04 pm

This reinforces one of the reasons that rolling an old 401k into an IRA isn't always the best advice. As I understand:

1. Old 401ks have at least equal and often greater creditor protection than IRAs (state dependent).
2. non-spousal inherited IRAs can't be rolled into rollover IRAs and then protected from bankruptcy (sort of a corollary of 1.)
3. rollover IRAs may interfere with backdoor Roth IRAs.

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Re: Inherited IRAs not exempt from bankruptcy

Post by bsteiner » Thu Jun 12, 2014 5:24 pm

manwithnoname wrote:All assets held in a retirement plan subject to ERISA are protected from claims of bankruptcy creditors, including IRA assets that are rolled over to the retirement plan. If IRA assets are rolled over to an employer plan there is no need to set up a trust. However inherited IRA assets cannot be rolled over.
After a participant dies, a qualified plan might not let a beneficiary take distributions over life expectancy. Many plans insist on paying the benefits in a lump sum. The Pension Protection Act allows a nonspouse beneficiary to roll the benefits over into an inherited IRA, to preserve the stretch.

Under this case, unless the inherited IRA is protected in bankruptcy under state law, the inherited IRA won't be protected (as to the beneficiary) in bankruptcy.

The participant could instead leave the retirement benefits to the beneficiary in trust rather than outright. That way, the retirement benefits (most likely in an inherited IRA after the participant's death) will be protected against creditors and spouses, and won't be included in the beneficiary's estate for estate tax purposes.

The trust can be created in the participant's Will, or in a separate trust instrument.

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Re: Inherited IRAs not exempt from bankruptcy

Post by manwithnoname » Thu Jun 12, 2014 5:30 pm

letsgobobby wrote:This reinforces one of the reasons that rolling an old 401k into an IRA isn't always the best advice. As I understand:

1. Old 401ks have at least equal and often greater creditor protection than IRAs (state dependent).
2. non-spousal inherited IRAs can't be rolled into rollover IRAs and then protected from bankruptcy (sort of a corollary of 1.)
3. rollover IRAs may interfere with backdoor Roth IRAs.
Distributions rolled over from a 401k or any other any employer plan to an IRA have the same protection in bankruptcy as they would have if funds had remained in the qualified plan as there is no limit on the amount of the Rollover that is protected from bankruptcy creditors. Aggregate Accumulations attributed to amounts contributed to an IRA/Roth are only protected to a limited amount, say 1.2M. Many state laws provide greater protections from both bankruptcy and non bankruptcy creditors than federal law (ERISA) because federal law doesn't prevent creditors from seizing retirement assets after they have been deposited in the debtors bank account while some state laws prohibit seizure of IRA assets by creditors after they been transferred to debtor's bank account. However no retirement assets are protected it is a fraudulent conveyance, is a claim for child support or spousal support under a QDRO or for taxes owed to the IRS.

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Re: Inherited IRAs not exempt from bankruptcy

Post by Quickfoot » Thu Jun 12, 2014 5:39 pm

Yep this is one reason why trusts are important.

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Eric
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Re: Inherited IRAs not exempt from bankruptcy

Post by Eric » Thu Jun 12, 2014 5:40 pm

Generally, a bankrupt debtor may elect one of two exemption schemes. With some exceptions, she may claim either the exemptions allowed by federal law or the exemptions allowed by state law.

I haven't reviewed the opinion yet, but I assume it affects only those debtors who are claiming the federal exemptions. So, for example, if the IRA beneficiary had lived in Texas, this probably wouldn't have been an issue (since our state exemptions are very generous, and include an exemption for inherited IRAs).

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Eric
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Re: Inherited IRAs not exempt from bankruptcy

Post by Eric » Thu Jun 12, 2014 5:46 pm

Raymond wrote:the amount in the inherited IRA was ~$300,000.

How much was spent in legal fees by the petitioners (Clark and his wife) to avoid having that amount included in the bankruptcy estate?
Should the debtors care? If they lose, they're spending the creditors' money. If they win, it's still better to keep some of the account (after attorneys' fees) than none of it.

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Re: Inherited IRAs not exempt from bankruptcy

Post by TIAX » Thu Jun 12, 2014 6:57 pm

Eric wrote:Generally, a bankrupt debtor may elect one of two exemption schemes. With some exceptions, she may claim either the exemptions allowed by federal law or the exemptions allowed by state law.

I haven't reviewed the opinion yet, but I assume it affects only those debtors who are claiming the federal exemptions. So, for example, if the IRA beneficiary had lived in Texas, this probably wouldn't have been an issue (since our state exemptions are very generous, and include an exemption for inherited IRAs).
No, that's incorrect. See page 2, footnote 1, of the opinion.

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Re: Inherited IRAs not exempt from bankruptcy

Post by Eric » Thu Jun 12, 2014 7:46 pm

TIAX wrote:No, that's incorrect. See page 2, footnote 1, of the opinion.
I'll cop to being partially incorrect. ;-) You do in fact get to choose between federal and state exemptions, as I stated. However, the Court ruled against the debtors even though they chose the state exemption. That's a surprising result, which I appreciate your bringing to my attention. I look forward to studying the opinion further to see why.

Edit: Per my post below, I may have conceded too quickly. See fuller explanation later in this thread.
Last edited by Eric on Thu Jun 12, 2014 9:38 pm, edited 1 time in total.

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Re: Inherited IRAs not exempt from bankruptcy

Post by TIAX » Thu Jun 12, 2014 8:13 pm

Eric wrote:
TIAX wrote:No, that's incorrect. See page 2, footnote 1, of the opinion.
I'll cop to being partially incorrect. ;-) You do in fact get to choose between federal and state exemptions, as I stated. However, the Court ruled against the debtors even though they chose the state exemption. That's a surprising result, which I appreciate your bringing to my attention. I look forward to studying the opinion further to see why.
Actually, what I was referring to is that whether a debtor elects to claim exemptions under federal or state law, the retirement funds exemptions are identical. See page 2, footnote 1, of the opinion:
Under §522 , debtors may elect to claim exemptions either under federal law, see §522(b)(2) , or state law, see §522(b)(3) . Both tracks permit debtors to exempt "retirement funds." See §522(b)(3)(C) (retirement funds exemption for debtors proceeding under state law); §522(d)(12) (identical exemption for debtors proceeding under federal law). Petitioners elected to proceed under state law, so we refer to §522(b)(3)(C) throughout.

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Re: Inherited IRAs not exempt from bankruptcy

Post by Eric » Thu Jun 12, 2014 8:20 pm

But "retirement funds" isn't the only operative provision, so I'm still puzzled by this result.

The case deals with 11 U.S.C. § 522(b). Subsection (b)(1) says that a debtor can protect property listed in subsection (b)(2) (the federal bankruptcy exemptions) or (b)(3) (the state exemptions, plus certain other property). Subsection (b)(3) is divided into three parts, as follows:
11 U.S.C. § 522(b)(3) wrote: (A) . . . any property that is exempt under Federal law, other than [federal bankruptcy law], or State or local law that is applicable on the date of the filing of the petition to the place in which the debtor’s domicile has been located . . .;
(B) any interest in property in which the debtor had, immediately before the commencement of the case, an interest as a tenant by the entirety or joint tenant to the extent that such interest as a tenant by the entirety or joint tenant is exempt from process under applicable nonbankruptcy law; and
(C) retirement funds to the extent that those funds are in a fund or account that is exempt from taxation under section 401, 403, 408, 408A, 414, 457, or 501(a) of the Internal Revenue Code of 1986.
Reading this statute, you would think (well, I would think) that the debtors can protect property described in any of the three subparts. The Supreme Court held that they can't protect the inherited IRA under (C), because these aren't "retirement funds." But the Court doesn't explain why the debtors can't protect the inherited IRA under (A). If they aren't "retirement funds," then by definition (C) shouldn't apply, and the debtors should still be able to claim an exemption under (A). So what gives? What am I missing here?

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Re: Inherited IRAs not exempt from bankruptcy

Post by TIAX » Thu Jun 12, 2014 8:41 pm

The question presented in the cert petition (page 2) only dealt with 522(b)(3)(C). I assume petitioner's counsel didn't think (A) applied.


Eric wrote:But "retirement funds" isn't the only operative provision, so I'm still puzzled by this result.

The case deals with 11 U.S.C. § 522(b). Subsection (b)(1) says that a debtor can protect property listed in subsection (b)(2) (the federal bankruptcy exemptions) or (b)(3) (the state exemptions, plus certain other property). Subsection (b)(3) is divided into three parts, as follows:
11 U.S.C. § 522(b)(3) wrote: (A) . . . any property that is exempt under Federal law, other than [federal bankruptcy law], or State or local law that is applicable on the date of the filing of the petition to the place in which the debtor’s domicile has been located . . .;
(B) any interest in property in which the debtor had, immediately before the commencement of the case, an interest as a tenant by the entirety or joint tenant to the extent that such interest as a tenant by the entirety or joint tenant is exempt from process under applicable nonbankruptcy law; and
(C) retirement funds to the extent that those funds are in a fund or account that is exempt from taxation under section 401, 403, 408, 408A, 414, 457, or 501(a) of the Internal Revenue Code of 1986.
Reading this statute, you would think (well, I would think) that the debtors can protect property described in any of the three subparts. The Supreme Court held that they can't protect the inherited IRA under (C), because these aren't "retirement funds." But the Court doesn't explain why the debtors can't protect the inherited IRA under (A). If they aren't "retirement funds," then by definition (C) shouldn't apply, and the debtors should still be able to claim an exemption under (A). So what gives? What am I missing here?

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Re: Inherited IRAs not exempt from bankruptcy

Post by Eric » Thu Jun 12, 2014 9:20 pm

TIAX wrote:The question presented in the cert petition (page 2) only dealt with 522(b)(3)(C). I assume petitioner's counsel didn't think (A) applied.
In which case we come full circle, and I provisionally retract my concession. ;-)

Let's go back to the beginning. I said earlier that under (b)(1), you can pick either the federal exemptions ((b)(2)) or the state exemptions ((b)(3)). But that's an oversimplification. Both (b)(2) and (b)(3) provide that certain property is protected regardless of which exemption scheme you select. One type of property that is protected, either way, is retirement funds held in a tax-favored account.

In this case, the debtors elected the state exemption scheme but did not seek to protect the inherited IRA under that scheme. Instead, the debtors relied on the special exemption for "retirement funds" that applies under either subsection. To interpret the Court's decision, we need to know why.

One possibility is that the state law at issue here did not protect inherited IRAs. (The debtors may have elected the state exemption scheme for other reasons, to protect other assets.) In that case, the debtors' counsel couldn't have invoked the protection of (b)(3)(A). Instead, they had to rely on (b)(3)(C) -- and that wasn't enough to save them.

If my theory is correct, then inherited IRAs should still be protected in a federal bankruptcy proceeding if they are protected under applicable state law. We need more information to confirm.
Last edited by Eric on Thu Jun 12, 2014 10:01 pm, edited 1 time in total.

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Re: Inherited IRAs not exempt from bankruptcy

Post by Eric » Thu Jun 12, 2014 9:35 pm

See this paragraph from the cert petition:
In enacting the "retirement funds" exemption, Congress sought to "expand the protection for tax-favored retirement plans or arrangements that may not already be protected under * * * state or federal law." In order to ensure that the exemption would be available "regardless of the state policy on exemptions," Congress enacted identically worded provisions for debtors who elect to pursue the state and federal exemption schemes, respectively. The same "retirement funds" exemption is therefore available to all debtors as a matter of federal law."
(Citations omitted, emphasis added.) So, the "retirement funds" exemption is an extra exemption, provided in addition to the state or federal exemptions otherwise available. ("Expand the protection.") If the inherited IRA is "already . . . protected under" state law, then the retirement funds exemption isn't needed and the inherited IRA should still be protected.

Of course, that's just the cert petition, not the court's opinion. But that is how the statute seems to read.
Last edited by Eric on Thu Jun 12, 2014 10:02 pm, edited 1 time in total.

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Re: Inherited IRAs not exempt from bankruptcy

Post by bsteiner » Thu Jun 12, 2014 9:47 pm

I would have thought the Supreme Court would have given some consideration to the fact that Internal Revenue Code Section 408(a) defines an IRA as being "for the exclusive benefit of an individual or his beneficiaries."

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Re: Inherited IRAs not exempt from bankruptcy

Post by TIAX » Thu Jun 12, 2014 10:07 pm

Eric wrote:
TIAX wrote:The question presented in the cert petition (page 2) only dealt with 522(b)(3)(C). I assume petitioner's counsel didn't think (A) applied.
In which case we come full circle, and I provisionally retract my concession. ;-)

Let's go back to the beginning. I said earlier that under (b)(1), you can pick either the federal exemptions ((b)(2)) or the state exemptions ((b)(3)). But that's an oversimplification. Both (b)(2) and (b)(3) provide that certain property is protected regardless of which exemption scheme you select. One type of property that is protected, either way, is retirement funds held in a tax-favored account.

In this case, the debtors elected the state exemption scheme but did not seek to protect the inherited IRA under that scheme. Instead, the debtors relied on the special exemption for "retirement funds" that applies under either subsection. To interpret the Court's decision, we need to know why.

One possibility is that the state law at issue here did not protect inherited IRAs. (The debtors may have elected the state exemption scheme for other reasons, to protect other assets.) In that case, the debtors' counsel couldn't have invoked the protection of (b)(3)(A). Instead, they had to rely on (b)(3)(C) -- and that wasn't enough to save them.

If my theory is correct, then inherited IRAs may still be protected in a federal bankruptcy proceeding if they are protected under applicable state law. We need more information to see.
You don't need any other information to "interpret the Court's decision." The Court held that Inherited IRAs may not be excluded from the bankruptcy estate under 522(b)(3)(C) (and the identical 522(d)(12). That's all. If you find cases holding that Inherited IRAs may be excluded under other sections, let us know.

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Re: Inherited IRAs not exempt from bankruptcy

Post by Eric » Thu Jun 12, 2014 10:19 pm

TIAX wrote:You don't need any other information to "interpret the Court's decision." The Court held that Inherited IRAs may not be excluded from the bankruptcy estate under 522(b)(3)(C) (and the identical 522(d)(12). That's all. If you find cases holding that Inherited IRAs may be excluded under other sections, let us know.
Have I offended you? That was not my intent. I think we're essentially in agreement: We both agree that the Supreme Court's decision should be interpreted narrowly, to say only that the special 522(b)(3)(C) (and (d)(12)) exemption does not apply to inherited IRAs. We also both agree that the decision does not speak to whether other exemptions apply to inherited IRAs; that question was not before the court.

I haven't looked for cases specifically addressing the applicability of the state law exemption to inherited IRAs (where state law provides such an exemption). I hadn't thought until now that this might be a controversial point. If you know of other relevant cases, I am sincerely very interested to learn about them. Thank you and best wishes.

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Re: Inherited IRAs not exempt from bankruptcy

Post by TIAX » Thu Jun 12, 2014 10:35 pm

Eric wrote:
TIAX wrote:You don't need any other information to "interpret the Court's decision." The Court held that Inherited IRAs may not be excluded from the bankruptcy estate under 522(b)(3)(C) (and the identical 522(d)(12). That's all. If you find cases holding that Inherited IRAs may be excluded under other sections, let us know.
Have I offended you? That was not my intent. I think we're essentially in agreement: We both agree that the Supreme Court's decision should be interpreted narrowly, to say only that the special 522(b)(3)(C) (and (d)(12)) exemption does not apply to inherited IRAs. We also both agree that the decision does not speak to whether other exemptions apply to inherited IRAs; that question was not before the court.
Not at all. I agree that we agree. :sharebeer

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Re: Inherited IRAs not exempt from bankruptcy

Post by Eric » Thu Jun 12, 2014 11:51 pm

We have also been agreeing swimmingly in several technical / law-geek PMs on this subject, from which we have spared our fellow Bogleheads. :D I did want to clarify a prior post of mine here, though, as I expressed something in an ambiguous way. There is a controversy in many states as to whether a general state exemption for "IRAs" also protects inherited IRAs (as a matter of state law). In Texas that's not an issue because, as of 2013, the exemption statute now explicitly refers to inherited IRAs. The issue I was raising above is whether, in states like Texas where the state exemption is clear, there could be something in federal law that would nevertheless prevent that exemption from being recognized. I believe the answer is no, and continues to be no after this Supreme Court decision.

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Re: Inherited IRAs not exempt from bankruptcy

Post by AviN » Sat Jun 14, 2014 12:48 am

Incidentally, I was visiting DC this week and attended the Supreme Court non-argument session when this ruling was made. :D

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Re: Inherited IRAs not exempt from bankruptcy

Post by manwithnoname » Sat Jun 14, 2014 6:59 am

It is my recollection that prior to the change in the bankruptcy law in 2005 to exempt IRA assets from creditors, there were bankruptcy cases where IRA assets were exempted from bankruptcy creditors under the provisions of NY law which had opted out of the federal bankruptcy exemptions in section 522(d). The New York opt out law is section 284 of the NY Debtor-creditor law which requires all debtors who file for bankruptcy to use the exemptions of D/C law section 282 which incorporates the exemptions from creditors claims available under CPLR sections 5205(c) and (d) for IRAs. The citations to the pre 2005 cases should still be listed under the cases in the D/C law or CPLR. DC 284 has been dormant since IRA assets became eligible for protection from bankruptcy creditors but there is no reason why the prior cases under NY law could not be applied to inherited IRAs.

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Re: Inherited IRAs not exempt from bankruptcy

Post by Tanelorn » Fri Aug 10, 2018 6:44 am

NY case where an inherited IRA is found not to be protected in bankruptcy.

https://www.lexology.com/library/detail ... 02beb89de5

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