Today, the Supreme Court ruled in Clark v. Rameker that inherited IRAs cannot be excluded from the bankruptcy estate using the “retirement funds” exemption under 11 U.S.C. 522(b)(3)(C). The full text of the Supreme Court’s opinion is available here. This has important implications in estate planning, particularly when determining whether to name individual beneficiaries or an accumulation trust as the beneficiary of IRAs and other qualified plans. The Supreme Court’s decision is yet another reason why naming a properly drafted accumulation trust as the beneficiary of a qualified plan would be beneficial.