FFL01 assembling firearms ??

[franklinarmory]

The magic number is 49 per year. At 50, you owe 11% FET to the TTB for rifles, and 10% for pistols. My understanding is that you would owe this whether you built 50 or more firearms, or if you sold 50 or more complete firearms in a KD fashion, or any combination thereof.

ITAR is $2250. There are exemptions, but you have to list each model with DDTC so that you can get a pass. You also have to renew that exemption every year. And like Kemasa said, you need to engrave your name on the firearm if you build a complete firearm. You could also apply for a mark variance so there is simply one name on the firearm instead of multiple 07ffls info on the firearm.

[Santa Cruz Armory]

All good information. Thanks guys.

[efillc]

The magic number is 49 per year. At 50, you owe 11% FET to the TTB for rifles, and 10% for pistols.

The 50-gun exemption applies only to Type 07 or Type 10 FFL's. Type 01's may not manufacture as part of their business, period. I know a Type 01 getting nailed for it now - he's lost his FFL and will be lucky to escape jail time - and he wasn't doing anywhere near 50 a year.

Given the Gunrunner / Fast & Furious fiascos, ATF is looking for reasons to make themselves look good. Busting a dealer for engaging in activity outside of what he's licensed for is an easy win.

[TCB Firearms]

As an 01 the wording is something to the effect of in a "regular" course of business. This is left up to the interpretation of the IO or Agent looking at you and your books. My first IO was cool woth kess than 25% of my volume, my current believes that number to be ZERO. That coupled with the back and forth of Melsons decisions on "gunsmithing" it is now a clouded purple haze of ???????? Best bet, if it is not drop in, and at a customers request on a customers weapon....get an 07 FFL. I stopped offering most gunsmithing as a result. maybe someday I will get an 07 SOT, until then drop in accessories only.

My $.02

[ugimports]

The magic number is 49 per year. At 50, you owe 11% FET to the TTB for rifles, and 10% for pistols. My understanding is that you would owe this whether you built 50 or more firearms, or if you sold 50 or more complete firearms in a KD fashion, or any combination thereof.

ITAR is $2250. There are exemptions, but you have to list each model with DDTC so that you can get a pass. You also have to renew that exemption every year. And like Kemasa said, you need to engrave your name on the firearm if you build a complete firearm. You could also apply for a mark variance so there is simply one name on the firearm instead of multiple 07ffls info on the firearm.

I think there are plenty of 07s that are not paying ITAR still. My ATF agent wasn't even sure of the ITAR requirements.