Florida statute section 22.14 provides for the exemption of the "proceeds of annuity contracts issued to citizens or residents of the state, upon whatever form...." from "any creditor of the person who is the beneficiary of such annuity contract, unless the ... annuity contract was effected for the benefit of such creditor."

Courts have held that payment stream created in a divorce property settlement agreement may not necessarily constitute an "annuity."

The Florida Supreme Court has held that the cash surrender value of annuities (ie. even prior to maturity) are exempt.

The statute generally requires that the proceeds of the annuity contract be issued to a citizen or resident of Florida but does not require the annuity contract itself to be issued to a citizen or resident of Florida.