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Coronavirus: examples where exemption from IHT would benefit front line workers

In a recent post, I attached my letter to the Chancellor dated 10th April 2020.

I also gave the text of examples. For convenience, a pdf of the examples is below:

Inheritance Tax examples re exemption for front line workers re coronavirus

 

Coronavirus: suggestion to extend the exemption from IHT to front line workers

A few days ago, I posted the text of a letter I have sent to the Chancellor.

Letter to the Chancellor

Attached here is a pdf of the letter itself (with one change, being changing his email address from his Constituency one to his 11 Downing Street one).

Inheritance Tax exemption for front line workers re coronavirus

Examples

I have also now written a few examples of why the exemption might help some front-line workers:

low net assets John, a soldier, dies with an estate below the Inheritance Tax threshold; the present exemption has no effect, not being needed.

married exemption Ann, a paramedic, married to Alan dies with a will leaving her estate to Alan; the present exemption has no effect, not being needed because of the exemption given to legacies to spouses and civil partners.

no valid will  Ahmed, a pilot, married to Saadia, dies intestate. Saadia receives part of Ahmed’s estate, and this part attracts exemption. But other parts pass by the rules of intestacy to other family members, and Inheritance Tax would be due, except for the armed forces exemption.

cohabiting siblings Jill, a police sergeant, has always lived with her brother Jack; she owns their home. She died having been attacked at work; her will leaves the house to Jack. Inheritance Tax would have been due, causing Jack to have to sell the house, had it not been for the armed forces exemption.

life insurance not in trust Neil and Lynne live together. Neil, an ambulance driver, dies during the course of attending an accident. Lynne thought that Neil’s estate was too small to be within the charge to Inheritance tax. Alas, like the majority of people (see footnote) the life assurance Neil had taken out was not written in trust and so his estate would have had to pay Inheritance Tax, where it not for the ‘armed forces’ exemption.

living together  Frankie and Johnny live together, and felt no need to get married. Frankie, a naval officer, dies in a diving accident. Inheritance Tax would have been payable except for the armed forces exemption.

NHS, Hospice and other front-line workers

There are Ahmeds, Jills, Frankies and Neils in the NHS, at hospices and in other front-line work. It would be a relatively easy amendment to the armed forces exemption- last changed in 2015 to bring in emergency personnel- to exempt them; relieving hardship for a few, and thanking all who day in, day out, put themselves at risk for us.

In summary

The exemption will help very few; it won’t be needed for many. But if it helps a few, or just one person who died trying to help others, isn’t it justified?

 

Origami 💙 for the NHS

One of my hobbies is origami, the art of paper-folding.
I’ve decided to fold NHS blue hearts 💙 and send them on cards to people I know who work at the NHS, in hospices, and in care homes.

Final model

 

It will take time to create the cards, but that is time for reflection and to thank all front-life workers who are doing their best to help people who are poorly with Covid-19 and all the other workload hospitals, hospices and care homes help with. And this is not forgetting GP surgeries, pharmacies, care in the community, bus drivers, binmen, policemen…the people we all rely on without really thinking how important they all are to every one of us.

Folding instructions

Others might like to do the same. Many people will have NHS workers and other front-line workers in their families or amongst their friends. If you would like to fold an origami 💙 for them, I have written folding instructions and they are here:

 

Origami heart for the NHS

Good luck, and I hope you enjoy the challenge of folding a 💙 heart (they’re not easy, and if you make one, well done!).

 

Coronavirus: suggestion to extend the exemption from IHT to front line workers

This morning, I wrote to the Chancellor, asking him to give consideration to extending the exemption from Inheritance Tax given to estates of armed services and emergency personnel to NHS, hospice and other front line workers in the fight against coronavirus.

Sadly, doctors, nurses and others have already lost their lives by being exposed to the virus in the course of their work; and more will die, too, before the outbreak is over.

Their estates in the main won’t attract Inheritance Tax; either by virtue of their size, or because of the exemption for bequests to spouses and civil partners. But some estates may trigger Inheritance Tax and could cause hardship. Some will die without having made a will, and thus their estates may pass partly to their spouse, partly to others (attracting Inheritance Tax); others will live as couples without being married or in civil partnerships; and others may be co-habiting siblings.

A sensibly drawn extension of the exemption should be possible: will reduce the financial hardship in some cases, and will be a recognition to all of the debt we owe to all front line workers.

The text of my leter to the Chancellor is pasted below.


 

10 April, 2020

The Rt Hon Rishi Sunak MP

Chancellor of the Exchequer

11 Downing Street

London SW1A 2AB

 

By email rishi.sunak.mp@parliament.uk

CEU.enquiries@hmtreasury.gov.uk

 

 

Dear Chancellor

Coronoavirus: extension of ‘armed forces’ Inheritance Tax exemption to NHS staff and others

Recommendation: extension of relief

This letter is to suggest that you give consideration to extending the present exemption in s154 Inheritance Tax Act 1984 given to estates of armed forces personnel and emergency personnel to NHS staff and other front-line workers who die when contracting coronavirus in the course of their work.

I have no significant personal interest in the proposal, not being a front-line worker, but consider that it would be a proportionate measure as an additional response to the pandemic. We are all indebted to the risks that such workers expose themselves to each and every day.

My outline proposal is based on the belief that NHS staff and volunteers of all grades, and such staff and volunteers in the nation’s hospices deserve whatever reasonable support the tax code can give them; and that there are many other front-line workers who similarly justify consideration.

I provide further details in the Appendix, including an offer to assist, if needed, in developing the proposals.

 

Yours faithfully

 

Allan Beardsworth MA ACA CTA

 

 

Appendix: recommendation to the Chancellor to extend the ‘armed forces’ Inheritance Tax exemption to the NHS and other front-line workers. Coronavirus response

 

Introduction

I am a Chartered Accountant and a Chartered Tax Advisor with over thirty years’ tax experience, principally as a partner in a Big 4 accountancy practice, but since 2015 practising on my own account.

I have no significant personal interest in the proposal. My wife is a primary school teacher but is presently off work due to her pre-existing medical conditions. For completeness, my younger daughter is a medical student; the proposals are not being put forward with a view to any personal gain, but because I think they would in some cases, maybe only a few, relieve hardship inflicted on families and loved ones.

Relief of hardship

A primary benefit of the proposed exemption is to provide a measure of relief from financial hardship.

As with the rest of the population, NHS staff and other front-line workers have a very broad range of financial and relationship circumstances. For those who die with a will bequeathing their estate to their spouse or civil partner, the provisions of s18 IHTA 1984 will lead to no Inheritance Tax.

But, for instance, (i) many people die intestate, so that sometimes not all their assets will be exemption; (ii) many people live as couples, outside a marriage or civil partnership; (iii) others live as co-habiting siblings and are presently not afforded exemption.

Recognition

A secondary benefit of the proposal is to provide a tangible financial benefit to the families of some of the front-line workers who lost their life due to the pandemic.

 

IHTA 1984, s 154: the existing legislation

There has been a long-standing exemption from Inheritance Tax for the estates of armed forces personnel who die in conflict or as a result of injuries sustained in the line of duty. The original provisions, also in previous death duty taxes referred to wounds inflicted instead of injuries sustained, but extensions in 2015 widened the scope of the relief.

The exemption was broadened following public consultation in 2014 by Finance Act 2015 section 75 to include from 19 March 2014 emergency service personnel and humanitarian aid workers who die in the line of duty. There are now three categories of exemption, listed below, the third being most relevant:

  • Death on active service of armed forces personnel;
  • Death of police constables or armed forced personnel who are targeted because of their status;

 

  • Death on active service of emergency services personnel; IHTA1984 s153A(1)(a) and (1)(b):
  • an injury sustained, accident occurring or disease contracted when that person was responding to emergency circumstances, IHTA84/S153A(1)(a), or
  • a disease contracted at some previous time, the death being due to, or hastened by, the aggravation of that disease when the person was responding to emergency circumstances, IHTA84/S153A(1)(b).

 

IHTA/S153A(6) and (7) have further conditions for emergency services personnel.

 

(6)“Emergency responder” means—

(a)a person employed, or engaged, in connection with the provision of fire services or fire and rescue services,

(b)a person employed for the purposes of providing, or engaged to provide, search services or rescue services (or both),

(c)a person employed for the purposes of providing, or engaged to provide, medical, ambulance or paramedic services,

(d)a constable or a person employed for police purposes or engaged to provide services for police purposes,

(e)a person employed for the purposes of providing, or engaged to provide, services for the transportation of organs, blood, medical equipment or medical personnel, or

(f)a person employed, or engaged, by the government of a state or territory, an international organisation or a charity in connection with the provision of humanitarian assistance.

(7)For the purposes of subsection (6)—

(a)it is immaterial whether the employment or engagement is paid or unpaid, and

(b)“international organisation” means an organisation of which—

(i)two or more sovereign powers are members, or

(ii)the governments of two or more sovereign powers are members.

 

Recommendation

 

I recommend you ask your officials to consider the extension to front-line workers. Since there would need to be boundaries, some thought would be needed, but as a suggestion, a new category of exemption could be introduced for deaths in which covid-19 was cited on death certificates, and in other cases where it was reasonable to assume that the death was due to or hastened by coronavirus.

 

I presume it will never be known whether a front-line worker contracted coronavirus at work, or on their journey to or from work, or outside of work. Hence my proposal for a “reasonable to assume” clause. HMRC already have experience of determining whether the ‘armed forces’ exemption applies: I would expect cases of difficulty with my proposal to be insignificant.

 

Linkage could sensibly be made to the Coronavirus Act 2020; for instance, its s1 (3) which stipulates that a reference in the Act to persons infected by coronavirus, however expressed, does not (unless a contrary intention appears) include persons who have been infected but are clear of coronavirus (unless re-infected).

 

I would be happy to help in any work needed to create a workable proposal; I will send a copy of this letter to my Member of Parliament, Mary Robinson, and to a few other fellow tax professionals and others who I think might be interested and might be able to promote or develop the idea, if it is considered to be a sensible proposal.

 

Exchequer cost

 

I presume that the cost to the Exchequer of this measure would be limited. The estates of many deceased front-line workers are likely to be exempt either by size or by s18 IHTA 1984 (spouse and civil partner exemption); the practical effect of the proposals is likely to be limited to the reduction of hardship in a few cases.

 

 

 

cc: Mary Robinson MP, by email   mary.robinson.mp@parliament.uk

 

Daily Chess Puzzle

I’ve decided to call a halt to my daily chess puzzles; the coronavirus pandemic has made me reflect on what’s important and how busy I have been these last too many years, and is causing me to make some changes. The work required to find, write up and post the puzzles has started to outweigh the pleasure of having an audience. Had I been less busy with work and other things I would have continued, but from now on, I will only post on an occasional basis, when I feel I have something interesting to share.

I started this blog many years ago, when I wanted to know how to write a website; and I’ve now done over 3,000 postings.

From now on, my postings will be infrequent,.

Stay safe.

 

 

 

 

 

Daily Chess Puzzle

Today’s problem is from the Candidates tournament.

As is my custom, I only say which side is to play: and not giving an idea if the move wins or otherwise, unless on occasion I think signposting would be helpful. Instead, the problems are posed with the instruction to decide what you would play, as in a game.

 

White to play

Nepomniachtchi Ian - Ding Liren (34...Qxe2)
Nepomniachtchi v Ding FIDE Candidates Tournament, Yekaterinburg, 23/3/2020

Solution

The first move White could play is 1 R6b2, but 1…Qb2! is an easy-to-spot tactic, since the Rb1 is tied to the first rank.

The second move I looked at for White is 1 Rb8, but then the fantastic 1…Re5! holds the balance, due to the back rank mate threat.

Nepomniachtchi Ian - Ding Liren (35...Re5).jpg

White has to play Rd8+ Rh8+! Qc8+ Qh3 wjem je jas a Carlsenesque advanntage:

Nepomniachtchi Ian - Ding Liren (39.Qxh3+).jpg

 

FEN

3b2k1/5pp1/1RQ5/r7/3p4/3P2Pp/4qP1P/1R5K w – – 0 35

Daily Chess Puzzle

Today’s problem is from the Candidates tournament.

As is my custom, I only say which side is to play: and not giving an idea if the move wins or otherwise, unless on occasion I think signposting would be helpful. Instead, the problems are posed with the instruction to decide what you would play, as in a game.

 

Black to play

Nepomniachtchi Ian - Ding Liren (33.Qc6).jpg
Nepomniachtchi v Ding FIDE Candidates Tournament, Yekaterinburg, 23/3/2020

Solution

Black played 1…Rc5 and soon lost, but 1…Rb6! 2 Rb6 Qe2! is equal. I’ll look at why tomorrow.

Nepomniachtchi Ian - Ding Liren (34...Qxe2).jpg

FEN

1r1b2k1/5pp1/1PQ5/r7/3p2q1/3P2Pp/1R2NP1P/1R5K b – – 0 33

Daily Chess Puzzle

Today’s problem is from an old edition of Chess Magazine. I don’t know which one, because, as is my habit, from time to time I photocopy a page to solve on walks or on trains etc; and my copy doesn’t show the magazine date.

As is my custom, I only say which side is to play: and not giving an idea if the move wins or otherwise, unless on occasion I think signposting would be helpful. Instead, the problems are posed with the instruction to decide what you would play, as in a game.

 

White to play

Martin Julian - Lammers Markus (21...Rfd8).jpg

 

J Martin v M Lammers, Bundesliga 16/10/2016

 

Solution

A pretty one today: I found it pleasing that 1 Rcd2! is so powerful: the rook can’t be captured, because the Rd8 is tied to defending the Ra8. So 1…Rdb8 2 Bh6! and npw the Rb8 is tied to the back rank, so the queen can’t be captured.

Martin Julian - Lammers Markus (23.Bh6).jpg

 

 

FEN

r2r2k1/1Q2pp1p/6p1/p1P5/8/1P2B3/qbR2PPP/3R2K1 w – – 0 22

Daily Chess Puzzle

Today’s problem is from an old edition of Chess Magazine. I don’t know which one, because, as is my habit, from time to time I photocopy a page to solve on walks or on trains etc; and my copy doesn’t show the magazine date.

Black to play and draw

Fernandez Daniel Howard - Jackson James P (50.f4).jpg

 

Daniel Fernandez v J Jackson, Newport Pagnall 5/11/2016

Solution

Black played the move I would have played, 1…Ke2, and lost: a pawn queens.

But 1…Rb3 or, I suspect technically better, 1…Rb2 and check-check-check.

For instance, 1…Rb2 2 f5 Rg2+

Fernandez Daniel Howard - Jackson James P (51...Rg2+).jpg

and 3 Kf6 Rh2, or 3 Kh5 Rf2.

If I were playing either colour, I wouldn’t know the correct evaluation: I would be in “play and pray” mode, thinking I should have studied Dvortesky’s endgame manual. But by playing around on my laptop, always hitting the unprotected pawn, I can see that the harassment causes the position to be drawn.

 

FEN

8/8/1r5P/p5K1/P4P2/8/8/3k4 b – – 0 50

Daily Chess Puzzle

Today’s problem is from an old edition of Chess Magazine. I don’t know which one, because, as is my habit, from time to time I photocopy a page to solve on walks or on trains etc; and my copy doesn’t show the magazine date.

As is my custom, I only say which side is to play: and not giving an idea if the move wins or otherwise, unless on occasion I think signposting would be helpful. Instead, the problems are posed with the instruction to decide what you would play, as in a game.

 

White to play: evaluate 1 Bf7+! Kf7

Flear Glenn C - Bhatia Kanwal K (20...Bxf3).jpg

 

Glenn Flear v K Bhatia, 4 NCL Reading 19/11/2016

Solution

Yesterday we saw the game continuation, 1… Rf7, which I find easy to compute. For some reason, I struggled more with 1…Kf7.

Eventually I saw 2 Re7+ Kg8[] and 3 Qh6 and it is game over.

Flear Glenn C - Bhatia Kanwal K (23.Qh6).jpg

I also found, and this is what took so much time, 3 f7+ Rf7[] 5 Re8+ Rf8[] 6 Rf8+ Kf8 7 Qf4+ and if 7…Kg8 8 Re1, with the threat of 9 Re8+ and 10 Qf8 mate, before deciding “long variation, bad variation” (it isn’t that bad: it wins) and taking a fresh look and seeing Qh6.

 

FEN

1n3rkb/r2p1p1p/5Pp1/2p5/2B5/q1B2b2/P2Q1PPP/R3R1K1 w – – 0 21