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So your saying with these identical trusts. Just divide your nfa items up on them at you see fit on the sch A.
Then if do a Restatement of Trust if need be for each trust uou have items on to clarify the changes to each trust.
How at that point would that work with atf. Would you need to send atf a copy of the Restatement of Trusts explaining what you have done.
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What I can say for sure is that you can change your trust all you want after your transfer is approved with the ATF, and you do not need to notify them at all.
You can't transfer an item from one trust to another without ATF approval and paying the tax. If you sent in a schedule A to the ATF showing progressive adds to trust with each new transfer, the ATF will have documentation that it was in fact a single trust with multiple items.
I am just theorizing that one could have created multiple identical trusts with the same name on the same date, have approval to transfer items to those various trusts by the ATF. If those are all true, then you could potentially have 10 items in 10 identical but individual trusts.
Creating your trust under the laws of Virginia helps here, since no notary is needed and you could easily create 100 trusts in a single day without help from a third party.