There was a tribal annuity case and it was showed as income. She got her check every six months. It was about $4,200 I think. Anyway, the Dallas bankruptcy laywer exemptions (wildcard) covered it so the issue was basically moot for me, but it’s income from another nation. Likewise, I had a client who had been teaching ESL in Japan. That money he made was income even though it was from a different country, since the code makes no distinction about the source of the money. I’ve been there on Indian land trusts. They cannot be sold to anyone but a member of the tribe unless the tribe approves the sale, and they won’t approve the sale, nor will another tribal member buy just to please the trustee. I know this is a common issue in Alaska. In my case I showed the UST case law from the USSC, and they still called the trustee in Alaska who sent them the same USSC case I gave them, and told my ch 7 trustee to get a grip. My guy didn’t get any checks for his land, or any tribal checks, but the land had value and the trustee wanted it to sell. No dice. It may depend on whether the fund that generates the payment is part of a spendthrift trust with anti-alienation provisions under non-bankruptcy (e.g. tribal) law. If so, then the corpus of the debtor’s interest would be protected under Patterson v. Shumate. I have my doubts (though I haven’t seen this very effectively litigated) that the trustee can take such a payment. As I recall, the payments are authorized under the Indian Gaming Rights Act (IGRA). As such, I opine that they are explicit restrictions on otherwise sovereign powers of the Indian Nations to do whatever the hell they want with the money. I believe the legislative authority bears me out. In fact, IGRA specifically sets out that such payments (IGRA payments I call them) are subject to the Internal Revenue Code. Nowhere does it state that such payments are subject to the Bankruptcy Code. Thus far, though, the case law as I remember it is very much in favor of the trustee, stating that the payment is property of the estate. However, those cases either simply assume that conclusion or the conclusion is thinly reasoned.