Originally Posted by
C4IGrant
....Now what has my interest is that the Treasury Dept. basically says that if a consumer (in the span of 1 year) buys enough components to build a weapon, then that counts against one of your 50 that you are allowed to build without collecting FET. If you go over 50 weapons, then you have to pay the 11% on
ALL 50!
Now IMHO, it is NEARLY impossible to keep track of what all components a customer buys and seeing if it adds up to a complete weapon....
C4
As a manufacturer that mails a check for FET to Treasury every two weeks of my life, this has really piqued my interest also.
I think it would be impossible to track such activity. When TTB (Tax and Trade Bureau) comes in to audit your FET activities, what records could possibly tell them what your customers are building?
For several years we sold Mauser barreled actions and Butler Creek synthetic stocks for those barreled actions, neither of which are taxable articles. Our distributors in turn resold those same items to their dealers. Surely the dealer sold them separately again, and FET never attached to these items, all the way into the consumers home.
Now you're saying that if you sold one of those barreled actions and one of those stocks, that sale (1 pc) would count towards your 50 per year allotment? What if the consumer buys the barreled action from you and the stock from the dealer down the street (or the internet)? Would that barreled action sale count towards your 50?
How in the world is it possible to know the actions of your consumers? As long as you sold the product legally, and did not assemble the non-taxable componenets into a taxable article, certainly there is no FET liability and I would argue, no manufacturing for ATF pruposes.
RRA certainly would never have to worry about the 50 piece per year threshold. The fact that they charge more for the components than the same componenets assembled, as many manufacturers do, leads me to believe it has more to do with discouraging component sales than any FET issue.
Michael Kassnar
President, K.B.I., Inc.
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