In general, the federal courts look to the state exemption laws of the state where the federal district is located. So, a federal court sitting in Texas would apply Texas’ exemption for annuities, including in a federal bankruptcy proceeding.

IRAs and other qualified accounts are subject to a $1 million cap in bankruptcy under the bankrutpcy reform act of 2005, but annuities and life insurance were not capped in that Act. So, if annuities or life insurance have an unlimited exemption in a state, they will also have that unlimited exemption in bankruptcy.

BTW, collection law does not typically distinguish between variable annuities and fixed annuities, i.e., they are all just “annuities” for creditor-debtor purposes.