New queries, issue 4464

IHT and a PSC

The inheritance tax implications of profits retained in a personal service company.

My client retired from his employment several years ago. However his former employer wanted to recruit someone with similar expertise but was unable to find a suitable replacement.

Consequently the firm asked my client to return to work for them but he has been doing this as a contractor and has traded through his own company. From the nature of his work I am reasonably happy that the IR35 rules do not apply.

The problem if it is one is that the client has not drawn all of the earnings from the company and reserves in the region of £200 000 have built up.

Given that the client and his wife have other assets that would use up the nil-rate band the concern is...