# “A Charging Order Is All They Can Get”: What California Courts Allow

> A creditor can only get a charging order, so you wait them out? California's statute allows foreclosure, and courts may reach the LLC itself. What works.

Source: https://ridleylawoffices.com/charging-order-protection/

By Eric Ridley, attorney, Ridley Law. Updated October 2026.

Part of our [money myths series](https://ridleylawoffices.com/money-myths/).

**The claim:** put your assets in an LLC and a creditor who wins a judgment against you can only get a “charging order.” You stop taking distributions, the creditor gets nothing, and sooner or later they settle cheap or go away.

**The verdict:** in California, the same statute that creates the charging order lets a court appoint a receiver and then foreclose on your interest and sell it (Corp. Code, § 17705.03, subd. (b)). California courts also let a creditor reach through the LLC to its own assets when the debtor controls it, and two published decisions say so in cases where the debtor tried this same strategy. A charging order never protected anything you own outside the LLC, and it does nothing at all when someone sues the LLC itself.

**4 steps**

Charging order, receiver, other orders, then foreclosure, all in Corp. Code § 17705.03

**$178M**

Distributed by the debtor’s LLC before judgment in *Curci*, while the creditor collected nothing after it

**10%**

Yearly interest on an unpaid California judgment, Code Civ. Proc. § 685.010

**10 + 10**

Years a judgment lasts, then renewable, interest included, §§ 683.020, 683.120

**0**

Published California appellate decisions we found applying a Wyoming, Nevada or Delaware charging-order statute

**Who gets paid when you follow this advice:** the states first. A California resident who runs an LLC from California owes California’s $800 annual tax no matter where the LLC was formed, and the formation state takes its own cut on top: a $60 minimum annual license fee in Wyoming (W.S. 17-29-209), $350 a year for Nevada’s annual list and business license (NRS 86.263, 76.130), and $400 a year in Delaware (6 Del. C. § 18-1107(b)). Then come the formation services, a registered agent in the formation state, and the seminars that sell “charging order protection” as the reason to buy all of it.

## What is a charging order?

A charging order is a court order that puts a lien on a debtor’s share of an LLC’s distributions and makes the LLC pay those distributions to the creditor instead of the debtor (Corp. Code, § 17705.03, subd. (a)).

It exists because an LLC interest is an odd kind of property. If a creditor could seize your membership and walk into the company’s meetings, your business partners would wake up in business with a stranger. So the law gives the creditor your money and leaves your partners alone. When a creditor goes after a member’s LLC interest, California’s Code of Civil Procedure points to this device: the interest “may be applied toward the satisfaction of the judgment by an order charging the judgment debtor’s interest” (Code Civ. Proc., § 708.310).

The statute calls the charging order “the exclusive remedy” for collecting from the debtor’s transferable interest (Corp. Code, § 17705.03, subd. (f)). That sentence is the entire sales pitch. Read the rest of the section and it stops working.

## What does California’s statute let a creditor do?

Four escalating things, all inside § 17705.03: the charging order, a receiver, any other order needed to make it work, and foreclosure and sale of your interest if distributions won’t pay the judgment within a reasonable time.

The receiver gets “the power to make all inquiries the judgment debtor might have made” (§ 17705.03, subd. (b)(1)). The receiver can ask for the books and the bank statements, and ask why distributions stopped the week the judgment was entered. The court can also “make all other orders necessary to give effect to the charging order” (subd. (b)(2)).

Then the step the pitch leaves out. “Upon a showing that distributions under a charging order will not pay the judgment debt within a reasonable time,” the court may “foreclose the lien and order the sale of the transferable interest” (subd. (b)(3)). The buyer gets your economic stake, not your vote, but you no longer own the right to the money. The plan of starving the creditor by never distributing now starves you instead.

California courts read the exclusivity clause narrowly. The Court of Appeal explained that it covers only satisfying a judgment “from the judgment debtor’s transferable interest,” and that going after the LLC’s own property is a different thing: “Reverse veil piercing is a means of reaching the LLC’s assets, not the debtor’s transferable interest in the LLC.” ([Curci Investments, LLC v. Baldwin (2017) 14 Cal.App.5th 214, 223](https://www.courtlistener.com/opinion/6238964/curci-invs-llc-v-baldwin/).)

California partnership law had allowed foreclosure on a charged interest long before the current LLC statute. In [Hellman v. Anderson (1991) 233 Cal.App.3d 840](https://www.courtlistener.com/opinion/2161004/hellman-v-anderson/), the court held a partner’s interest can be foreclosed and sold even when the other partners object, “provided the foreclosure does not unduly interfere with the partnership business.” That’s a partnership case. For LLCs, the statute itself now authorizes foreclosure.

## How do Wyoming, Nevada and Delaware differ from California?

Their statutes expressly bar foreclosure and say they cover single-member LLCs. California’s statute authorizes foreclosure and says nothing about single-member LLCs either way.

| Question | Wyoming | Nevada | Delaware | Florida | California |
| --- | --- | --- | --- | --- | --- |
| Charging order called the exclusive remedy | Yes, W.S. 17-29-503(g) | Yes, NRS 86.401(2)(a) | Yes, 6 Del. C. § 18-703(d) | Yes, with exceptions, Fla. Stat. § 605.0503(3) | Yes, Corp. Code § 17705.03(f) |
| Foreclosure on the interest | Barred | Barred | Barred | Allowed for single-member LLCs only, § 605.0503(4) | **Allowed**, § 17705.03(b)(3) |
| Receiver or court-ordered inquiries | Inquiries barred | Inquiries barred | “Other legal or equitable remedies” barred | Not addressed | **Receiver with full inquiry power**, (b)(1) |
| Says it protects single-member LLCs | Yes, “the sole member” | Yes, “one member or more than one member” | Yes, “1 member or more than 1 member” | No: a foreclosure buyer becomes the member, § 605.0503(5) | Silent |
| Bars reaching the LLC’s own assets | Yes, “or from the assets of the limited liability company” | Not addressed | Yes, § 18-703(e) | No: preserves alter ego and fraudulent-transfer law, § 605.0503(7) | **No**: reverse piercing allowed, *Curci* |
| Applied in a California court | Written for their own LLCs. We found no published California appellate decision applying any of them to a member sued in California. | Not by any published California decision we found | Yes, for California LLCs | | |

The out-of-state statutes are real, and the promoters quote them accurately. What they skip is where your creditor sues. A Ventura County driver who rear-ends you sues you in Ventura County, and the judgment is enforced in California. California’s choice-of-law rule for foreign LLCs gives the formation state “the organization of the limited liability company, its internal affairs,” and a member’s liability “for the debts, obligations, or other liabilities of the limited liability company” (Corp. Code, § 17708.01, subd. (a)). Your personal creditor collecting your personal debt is neither of those. We searched for a published California appellate decision applying another state’s charging-order statute in that situation and found none. The full comparison of what out-of-state formation does and doesn’t buy is on our page about [why out-of-state LLCs won’t protect California assets](https://ridleylawoffices.com/the-asset-protection-industrial-complex-why-out-of-state-llcs-wont-save-you-in-california/).

## Can a California court reach the LLC’s own assets?

Yes. Two published Court of Appeal decisions hold that a creditor of an LLC member can seek to add the LLC itself as a judgment debtor through reverse veil piercing, and both involved a debtor running the charging-order play.

**Curci Investments, LLC v. Baldwin (2017).** James Baldwin formed JPB Investments, a Delaware LLC, and held 99 percent of it; his wife held 1 percent. A creditor got a judgment against him of about $7.2 million in October 2012 and a charging order on his interest. The court recited that the creditor “has received no money as a result of the charging order,” even though the LLC had distributed about $178 million to Baldwin and his wife between 2006 and 2012. After the judgment, distributions stopped. The trial court had refused to consider reverse piercing at all. The Court of Appeal reversed, held it “may be available in this case,” and sent the case back for the trial court to decide. It distinguished the corporate case that had rejected outside reverse piercing ([Postal Instant Press, Inc. v. Kaswa Corp. (2008) 162 Cal.App.4th 1510](https://www.courtlistener.com/opinion/2291272/postal-instant-press-inc-v-kaswa-corp/)), noting there “simply is no ‘innocent’ member” of the LLC, because the wife was liable for the community debt too. ([14 Cal.App.5th 214, 218-224](https://www.courtlistener.com/opinion/6238964/curci-invs-llc-v-baldwin/).)

Notice the LLC was formed in Delaware, whose statute says a member’s creditor has no right to remedies against the LLC’s property (6 Del. C. § 18-703(e)). The California court applied California’s alter ego law and held reverse piercing may be available anyway.

**Blizzard Energy, Inc. v. Schaefers (2021).** The debtor owed a $3.825 million fraud judgment and owned 50 percent of two LLCs with his wife. He wrote to his accountant that “the worst thing that can happen \[is\] that they get a charging order,” and that the creditor would collect nothing because the LLCs wouldn’t make distributions for a long time. The court quoted the letter, upheld the finding that the LLC was his alter ego, and rejected the argument that a charging order was the creditor’s exclusive remedy, following *Curci*. It sent the case back only so the trial court could weigh whether the wife, who might be an innocent 50 percent owner, would be unfairly harmed. ([Blizzard Energy, Inc. v. Schaefers (2021) 71 Cal.App.5th 832](https://www.courtlistener.com/opinion/5298617/blizzard-energy-inc-v-schaefers/).)

**The lesson from both cases:** the “wait them out” strategy isn’t a defense. It’s evidence. A debtor who controls the LLC, stops distributions when the judgment lands, and says why, has written the creditor’s reverse-piercing motion for them.

Reverse piercing still isn’t automatic. The creditor has to prove alter ego, and the court weighs the equities, including harm to co-owners who had nothing to do with the debt. That’s the one place a real co-owner helps you. A spouse or child holding a token percentage usually doesn’t.

## Does a single-member LLC get charging-order protection?

Not reliably. Courts elsewhere have refused to apply it to single-member LLCs, Florida’s statute now allows foreclosure on them, no California decision promises it, and in bankruptcy a trustee takes the whole interest.

The reason is the one the charging order was built on. It protects the other members. With no other members, there’s nothing to protect. A Colorado bankruptcy court said: “In a single-member entity, there are no non-debtor members to protect.” The trustee became the substituted member and could have the LLC sell its property. ([In re Albright (Bankr. D.Colo. 2003) 291 B.R. 538, 541](https://www.courtlistener.com/opinion/1924068/in-re-albright/).) The Florida Supreme Court held a court “may order a judgment debtor to surrender all right, title, and interest in the debtor’s single-member LLC to satisfy an outstanding judgment” ([Olmstead v. Federal Trade Commission (Fla. 2010) 44 So.3d 76, 83](https://www.courtlistener.com/opinion/2537285/olmstead-v-federal-trade-commission/)). Florida’s current statute lets a court foreclose on a single-member interest, and the buyer becomes the member (Fla. Stat. § 605.0503(4), (5)).

Bankruptcy is its own problem. An interest of the debtor becomes property of the estate “notwithstanding any provision in an agreement, transfer instrument, or applicable nonbankruptcy law” that “restricts or conditions transfer of such interest” (11 U.S.C. § 541(c)(1)(A)). An Arizona bankruptcy court held that when a non-manager member of a family LLC filed Chapter 7, the trustee “acquires all of the member’s rights and interests” ([In re Ehmann (Bankr. D.Ariz. 2005) 319 B.R. 200](https://www.courtlistener.com/opinion/1521947/movitz-v-fiesta-investments-llc/)). *Albright*, *Olmstead* and *Ehmann* are out-of-state and federal decisions. They don’t bind a California court, but they’re what a California creditor’s lawyer will cite.

| Who owns the LLC | Foreclosure under § 17705.03(b)(3) | Reverse veil piercing | Bankruptcy | Hidden cost |
| --- | --- | --- | --- | --- |
| You alone | Available | Highest risk: no innocent member to weigh | Trustee steps into your shoes, as in *Albright* | None, except false confidence |
| You, plus a spouse or child with a small slice | Available | High: *Curci* was 99/1 with a spouse liable for the debt | Trustee takes your interest, § 541(c)(1) | The family member now owns a real piece, which their own divorce or creditors can reach |
| You, plus real co-owners who run a real business | Available, but a court weighs harm to the business | Lower: innocent members count, as in *Blizzard* | Trustee takes your economic rights | Your partners can pay the judgment and step into the creditor’s shoes, § 17705.03(d) |

## Can you wait out a creditor by never taking distributions?

The math runs the other way: a California judgment earns 10 percent simple interest a year, lasts ten years, and can be renewed for ten more with the interest folded in, while you can’t touch the LLC’s money either.

Interest on an unpaid money judgment accrues “at the rate of 10 percent per annum” (Code Civ. Proc., § 685.010, subd. (a)(1)). The lower 5 percent rate applies only to smaller medical and consumer debts, not to a car-accident or business judgment (subd. (a)(2)). A judgment is enforceable for ten years (§ 683.020), the creditor can renew it for another ten (§ 683.120), and the renewed amount is everything “required to satisfy the judgment on the date of the filing of the application for renewal,” accrued interest included (§ 683.150, subd. (c)).

Meanwhile the tax bill lands on you. A partner owes tax on “his distributive share, whether or not distributed” (Treas. Reg. § 1.702-1(a)). A single-member LLC is disregarded, so its income is yours. Freeze distributions to starve the creditor and you’re paying income tax every year on money you’ve ordered your own company not to give you.

| | The creditor | You |
| --- | --- | --- |
| Cash this year | None from the LLC | None from the LLC |
| The debt | Grows 10% a year, § 685.010 | Grows 10% a year |
| Income tax on LLC profits | None | Yours, distributed or not, Treas. Reg. § 1.702-1(a) |
| Next move available | Receiver, foreclosure, reverse piercing | Waiting |
| Deadline pressure | Ten years, renewable | None that helps you |

## Does the creditor get stuck paying tax on a K-1?

Probably not. The “poison pill” theory leans on an IRS ruling about an assignee who took control of a partnership interest, and a creditor holding a charging order takes no control at all.

The pitch says the creditor will receive a K-1 for your share of the LLC’s income, owe tax on money it never received, and drop the case. It traces to Rev. Rul. 77-137, 1977-1 C.B. 178. As California’s State Board of Equalization described it, a limited partner assigned his entire interest and agreed to exercise any remaining powers “solely in favor of and in the interest of the assignee,” and the IRS treated the assignee as a substituted partner for income tax purposes. The Board read the ruling as turning on the assignee getting substantially all dominion and control over the interest ([Appeal of Goodin (Cal. St. Bd. of Equal. 1989) 89-SBE-016](https://ota.ca.gov/wp-content/uploads/sites/54/2022/03/89-sbe-016.pdf)).

A charging order is the opposite. It’s a lien on distributions (Corp. Code, § 17705.03, subd. (a)), and even a buyer at a foreclosure sale “does not thereby become a member” and gets no vote or management role (§ 17705.03, subd. (b)(3); § 17705.02, subd. (a)(3)). We found no statute, regulation or published ruling that taxes a charging-order creditor on income it never receives. The member who keeps the interest keeps the tax, as the table above shows.

## Which lawsuits does a charging order even matter for?

Only “outside” claims, where someone sues you personally and wants your LLC interest. When someone sues the LLC, the charging order never comes up, and it never protected your other assets.

An LLC’s liability shield runs the other direction from the charging order. The LLC’s debts “are solely the debts, obligations, or other liabilities of the limited liability company” (Corp. Code, § 17703.04, subd. (a)(1)), which protects your house and savings from a claim against the LLC. That shield has its own limits: you remain liable for “the member’s participation in tortious conduct” and for any guarantee you sign (subd. (c)), and alter ego can make you liable for the LLC’s debts (subd. (b)).

| The claim | Who gets sued | Does the charging order matter? | What protects you |
| --- | --- | --- | --- |
| You cause a car accident | You | Only for your LLC interest. Your other assets are exposed. | Auto and umbrella insurance |
| A tenant is hurt at the LLC’s rental | The LLC | No. The LLC’s building and accounts are reachable directly. | Landlord liability insurance and a separate LLC for each property |
| You personally caused the tenant’s injury | The LLC and you | No | Insurance. Section 17703.04(c) makes you liable for your own torts |
| The LLC defaults on a loan you guaranteed | The LLC and you | No | Not signing the guarantee, if the lender allows it |
| A business judgment against you personally | You | Yes, until foreclosure or reverse piercing | Insurance, exemptions, and planning done before the claim |

## What if you move assets into an LLC after a claim comes up?

A court can undo the transfer. California’s Uniform Voidable Transactions Act reaches transfers made “with actual intent to hinder, delay, or defraud any creditor,” whether the claim arose before or after the transfer (Civ. Code, § 3439.04, subd. (a)).

The statute lists what courts look at, and an LLC funded in a hurry checks most of the boxes: a transfer to an insider, the debtor keeping control of what was transferred, a transfer made after being “sued or threatened with suit,” and a transfer of substantially all the debtor’s assets (§ 3439.04, subd. (b)). The creditor can then have the transfer set aside, freeze the asset, get a receiver, or levy on it directly (§ 3439.07). The usual deadline is four years from the transfer, or one year from when the creditor could reasonably have discovered it, with an outside limit of seven years (§ 3439.09).

It can also be a crime. Fraudulently conveying or concealing property “with intent to defraud, hinder or delay” creditors is punishable by up to a year in county jail (Pen. Code, § 154, subd. (a)), and being a party to a fraudulent conveyance is a misdemeanor (Pen. Code, § 531).

## When does an LLC help?

An LLC earns its $800 a year when it runs a real business or holds rental property, because it keeps the business’s liabilities away from your personal assets. That’s the job it’s built for.

Holding each rental in its own California LLC means a tenant’s claim at one property can’t reach the others. A real multi-member business with an operating agreement gives the charging order the job it was designed for: protecting your partners, and making a court think hard before forcing a sale of your stake. Neither of these needs Wyoming. See [whether a rental belongs in an LLC](https://ridleylawoffices.com/llc-for-rental-property-california/), [holding company LLCs](https://ridleylawoffices.com/holding-company-llc-california/), and [what an operating agreement should cover](https://ridleylawoffices.com/california-llc-operating-agreement/). If you want one formed, Ridley Law’s flat fee is $2,500 for a single-owner LLC, including the first statement of information, and $5,500 for an LLC with more than one owner.

## What should you do instead?

1. Buy enough insurance first Liability coverage and an umbrella policy pay claims and fund your defense. A charging order does neither.
2. Use the protections California already gives you The homestead exemption protects equity in your home (Code Civ. Proc., § 704.730), and qualified retirement accounts carry strong protection. Our [California asset protection guide](https://ridleylawoffices.com/asset-protection-california/) walks through each one.
3. Form entities for business reasons, early An LLC set up years before any claim, for a real business purpose, is hard to attack. One set up the week a demand letter arrives is the textbook voidable transfer.
4. Run the LLC like a separate company Its own bank account, its own books, no personal bills paid from it, and distributions that follow the operating agreement. That’s what defeats an alter ego or reverse-piercing claim.
5. Get advice before there’s a claim Planning done before a creditor exists is legitimate. Planning done after is evidence.

## Frequently asked questions

### Is a charging order the only remedy against an LLC member in California?

For collecting from the member’s transferable interest, yes, but the same statute lets the court appoint a receiver and foreclose on and sell the interest (Corp. Code, § 17705.03, subds. (b), (f)), and California courts allow reverse veil piercing to reach the LLC’s own assets.

### Can a creditor foreclose on my LLC interest in California?

Yes, on a showing that distributions under the charging order won’t pay the judgment within a reasonable time. The buyer gets your economic rights, not your vote.

### Does a Wyoming or Nevada LLC give me better charging-order protection?

Their statutes say so, but we found no published California appellate decision applying them to a California resident sued here, and *Curci*, the leading California case, held reverse piercing may be available against a Delaware LLC. You also pay California’s $800 tax anyway.

### Does a single-member LLC have charging-order protection in California?

We found no California decision that says it does. Courts elsewhere have refused it, and in bankruptcy a trustee takes the whole interest.

### What is reverse veil piercing?

It lets a creditor of an LLC member treat the LLC as the member’s alter ego and collect from the LLC’s own assets. California courts have held it may be available against an LLC (*Curci*, 2017; *Blizzard Energy*, 2021).

### Will a creditor with a charging order have to pay tax on my LLC’s income?

Unlikely. The IRS ruling behind that theory involved an assignee with control over the interest, and a charging-order creditor has none. The member who still owns the interest owes the tax.

### Can I put assets into an LLC after I’ve been sued?

You can sign the paperwork, but a court can undo the transfer under Civil Code § 3439.04, and doing it to defeat a creditor can be a crime under Penal Code §§ 154 and 531.

This page is general information about California law as of its update date. It isn’t legal, tax, or investment advice for your situation, and reading it doesn’t create an attorney-client relationship.

More myths from social media, checked against the actual rules: [the money myths series](https://ridleylawoffices.com/money-myths/).

**Related reading:** [why out-of-state LLCs won’t protect California assets](https://ridleylawoffices.com/the-asset-protection-industrial-complex-why-out-of-state-llcs-wont-save-you-in-california/); [the anonymous Wyoming and Nevada LLC pitch](https://ridleylawoffices.com/anonymous-llc/); [asset protection in California: what works and what’s a myth](https://ridleylawoffices.com/asset-protection-california/); [assigning an LLC membership interest](https://ridleylawoffices.com/llc-membership-interest-assignment-california/); [piercing the corporate veil in California](https://ridleylawoffices.com/piercing-corporate-veil-california/); [putting your house in an LLC](https://ridleylawoffices.com/house-in-llc-california/).

Sources

- [California Legislature, Corp. Code § 17705.03](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CORP&sectionNum=17705.03) (eff. 2013-01-01)
- [California Legislature, Corp. Code § 17705.02](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CORP&sectionNum=17705.02) (eff. 2016-01-01)
- [California Legislature, Corp. Code § 17703.04](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CORP&sectionNum=17703.04) (eff. 2013-01-01)
- [California Legislature, Corp. Code § 17708.01](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CORP&sectionNum=17708.01) (eff. 2013-01-01)
- [California Legislature, Code Civ. Proc. § 708.310](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CCP&sectionNum=708.310) (current)
- [California Legislature, Code Civ. Proc. § 685.010](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CCP&sectionNum=685.010) (eff. 2024-01-01)
- [California Legislature, Code Civ. Proc. §§ 683.020](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CCP&sectionNum=683.020), [683.120](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CCP&sectionNum=683.120), [683.150](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CCP&sectionNum=683.150) (current)
- [California Legislature, Civ. Code §§ 3439.04](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV&sectionNum=3439.04), [3439.07](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV&sectionNum=3439.07), [3439.09](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV&sectionNum=3439.09) (eff. 2016-01-01)
- [California Legislature, Pen. Code § 154](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PEN&sectionNum=154) and [§ 531](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PEN&sectionNum=531) (current)
- [Wyoming Legislature, W.S. 17-29-503 and 17-29-209](https://wyoleg.gov/statutes/compress/title17.pdf) (current)
- [Nevada Legislature, NRS 86.401](https://www.leg.state.nv.us/nrs/nrs-086.html#NRS086Sec401); [NRS 86.263](https://www.leg.state.nv.us/nrs/nrs-086.html#NRS086Sec263); [NRS 76.130](https://www.leg.state.nv.us/nrs/nrs-076.html#NRS076Sec130) (current)
- [Delaware Code, 6 Del. C. § 18-703](https://delcode.delaware.gov/title6/c018/sc07/index.html); [§ 18-1107](https://delcode.delaware.gov/title6/c018/sc11/index.html) (current)
- [Florida Legislature, Fla. Stat. § 605.0503](http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0600-0699/0605/Sections/0605.0503.html) (current)
- [U.S. Congress (via Cornell LII), 11 U.S.C. § 541](https://www.law.cornell.edu/uscode/text/11/541) (current)
- [Treasury (via Cornell LII), Treas. Reg. § 1.702-1](https://www.law.cornell.edu/cfr/text/26/1.702-1) (current)
- [California Court of Appeal, Curci Investments, LLC v. Baldwin (2017) 14 Cal.App.5th 214](https://www.courtlistener.com/opinion/6238964/curci-invs-llc-v-baldwin/) (2017-08-10)
- [California Court of Appeal, Blizzard Energy, Inc. v. Schaefers (2021) 71 Cal.App.5th 832](https://www.courtlistener.com/opinion/5298617/blizzard-energy-inc-v-schaefers/) (2021-11-18)
- [California Court of Appeal, Postal Instant Press, Inc. v. Kaswa Corp. (2008) 162 Cal.App.4th 1510](https://www.courtlistener.com/opinion/2291272/postal-instant-press-inc-v-kaswa-corp/) (2008-05-20)
- [California Court of Appeal, Hellman v. Anderson (1991) 233 Cal.App.3d 840](https://www.courtlistener.com/opinion/2161004/hellman-v-anderson/) (1991-08-26)
- [U.S. Bankruptcy Court, D. Colo., In re Albright (2003) 291 B.R. 538](https://www.courtlistener.com/opinion/1924068/in-re-albright/) (2003-04-04)
- [U.S. Bankruptcy Court, D. Ariz., In re Ehmann (2005) 319 B.R. 200](https://www.courtlistener.com/opinion/1521947/movitz-v-fiesta-investments-llc/) (2005-01-13)
- [Supreme Court of Florida, Olmstead v. FTC (2010) 44 So.3d 76](https://www.courtlistener.com/opinion/2537285/olmstead-v-federal-trade-commission/) (2010-06-24)
- [California State Board of Equalization, Appeal of Goodin, 89-SBE-016 (describing Rev. Rul. 77-137, 1977-1 C.B. 178)](https://ota.ca.gov/wp-content/uploads/sites/54/2022/03/89-sbe-016.pdf) (1989)

**Related reading:** [why an offshore trust doesn’t fix this](https://ridleylawoffices.com/offshore-asset-protection-trust-california/).