Winding down UK Ltd company - subject to NIIT?

Hello, would appreciate any opinions on my situation, specifically whether I would be subject to NIIT.

I'm considering winding down my 1-man UK Ltd company which I have used for IT contracting for many years and have accumulated retained earnings in over the NIIT threshold.  Plan is to do MVL and claim Entrepreneur's Relief in the UK to get the money out at 10%. The company has never had any passive income (not even interest).  Would these proceeds be subject to NIIT?

Thanks

Sounds complex to me - I'll be interested to hear the replies you get.

Presumably you've been filing form 5471 and also from 8992 (GILTI)? - if you have, then presumably some amount of the retained earnings in your company has found its' way on to your 1040 filing and been subject to tax already?

Is an alternative for your to retain the company and pay yourself a £40K annual salary, 100% of which you roll into a pension (such as a SIPP)? - thereby reducing the retained earnings and not having to pay 10% CGT (via Entrepreneurs Relief) - just a thought......

I would expect all of the income would already have been subject to US tax under the SubPart F rules. If not SubPart F - then transition tax and more recently GILTI would have eaten up all the income. I'd be discussing planning with company's existing accountants.