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I have my Type06. I made quite a bit of extra money at times. But it waxes and wanes. I mostly just did local shops. Did pretty good. Your liability insurance will eat into your bottom line if you don't have a steady income at it. I carreid mine with a place in Kentucky that does riders for all kinds of firearm related businesses, ranges and the like. My insurance was something like $140 a month. But that is liability.

Keeping track of all your incoming and outgoing for taxes is a b%tch.

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We're not quitting our day jobs. 06 FFL will compliment 01 and 07 ffls.

I was kind of dragging my hook for Flame Thrower.

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This is why I never got into it.  Tough times right now to try to make $$ reloading ammo... just my opinion.

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The 07 FFL will cover the 01 and 06... So you'd only need an 07 to do as you describe.

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Smokeless storage is not a problem.

Black powder = Problems

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Why would anyone that didn't export want to buy an ITAR license?

There's no way I would tread that morass.

TITLE 22––FOREIGN RELATIONS

CHAPTER I––DEPARTMENT OF STATE

PART 122 –– REGISTRATION OF MANUFACTURERS AND EXPORTERS

Section Contents
§ 122.1   Registration requirements.
§ 122.2   Submission of registration statement.
§ 122.3   Registration fees.
§ 122.4   Notification of changes in information furnished by registrants.
§ 122.5   Maintenance of records by registrants.

Authority:   Secs. 2 and 38, Public Law 90–629, 90 Stat. 744 (22 U.S.C. 2752, 2778); E.O. 11958, 42 FR 4311; 1977 Comp. p. 79, 22 U.S.C. 2651a.
Source:   58 FR 39298, July 22, 1993, unless otherwise noted.
§ 122.1   Registration requirements.
(a) Any person who engages in the United States in the business of either manufacturing or exporting defense articles or furnishing defense services is required to register with the Directorate of Defense Trade Controls. For the purpose of this subchapter, engaging in the business of manufacturing or exporting defense articles or furnishing defense services requires only one occasion of manufacturing or exporting a defense article or furnishing a defense service. Manufacturers who do not engage in exporting must nevertheless register.

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Knew there was no need for ITAR tax

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Read section 122 again; also do a search in the FFL forum here...

TR

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I'm not going to look right now - what is the definition of defense article?

There have been some raging debates from time to time about this topic on another site that has several members engaged in the manufacture of firearms and ammunition.  I recommend getting advice directly from the US State Department.

Such as the sub paragraphs of the section you provided.

US Department of State - ITAR 2010

The US Munitions List

Registration

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I can tell you what Sam Grave's office said...... "This tax shouldn't apply to you."

Workin this from a few different angles. Sam Grave's office is calling me back next week after having researched some more and a phone call or two to The Dictorate of Defense Trade Controls.

Every single one of you with any interest in this matter at all should contact your U.S. Congressman.

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Maybee, your misunderstanding what is the current course of action. As it stands per a conversation I had with ITAR enforcement it is the rule to register. With registration comes the $2,250.00.

You were right.

In this conversation with enforcement i  brought up the fact the fee makes it impossible for the little guy to get a start. There was a long pause on the other end.............. then a reply of, you're right. It does.

I'm still not convinced there isn't a loophole but if there isn't, I intend going through the only course of action available is my elected official.

That aid's response.... his name is Mark. Mark's response after a lengthy discussion of our operation and a tour of the ITAR website was encouraging when he said this fee should not apply to you.

Now. Mr. Brickeyee. If you want to piss on my parade go ahead. I'm pretty thick skinned. Both phone calls today were made to Washington DC.

Several here have contacted me via IM and E-mail asking for updates so this is me following through. Have contacted some friends in the business,

they were caught off guard and if they have to pay they will. They'll follow lead and contact their Congressmen first. I'm prepared to lobby this in D.C.

if need be.

120.3 Policy on destinguishing and determining defense articles and services

An article or servcie may be designated or determined in the future to be a defense article (see120.6) or defense service (see 120.9) if it:
(a) is specifically designed, deverloped, configured, adapted, or modified for a military application, and
(i) Does not have predominant civil applications, and
(ii) Does not have performance equivelent (defined by form, fit and function) to those of an article or service used for civil applications; or
(b) Is specifically designed, developed, configured, adapted, or modified for a military application. and has significant military or intelligence applicability such that control under this subchapter is necessary.

The intended use of this article or service after it's export (i.e., for military or civilian purpose) is not relevant in determining whether the article or service is subject to the controls of this subchapter. Any item covered by the U.S. Munitions list must be within the catagories of the U.S. Munitions list. The scope of the U.S. Munitions list shall be changed only by amendments made peuersuant to section 38 of the Arms Export Control Act (22 U.S.C. 2778)

An article or service may be designated or determined in the future to be a defense article

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The way that reads to me Flamethrower is if DOD decides to install a guided dust collection system on vacuum sweepers in Aircraft Carriers, then every company manufacturing a like guided, dust collection vacuum sweeper will be subject to ITAR registration and subsequently subject to $2,250.00 registration fee. So anyone manufacturing a weapon or cartridge is subject to ITAR registration. DDTC says the same thing.


On a note of optimism. My U.S. Congressman is Sam Graves. He is one of maybe two Congressman who holds an FFL. This issue has been assigned to an aid who is not in this week. He will be in touch next week and a file has been created to work from.


NRA has a legal designate assigned to every state in the U.S.. Missouri"s designate is Liz Williams, she works lock in step with Sam Graves and his aids. She knows every person on his staff by first name it seems. I have spoken with Liz Williams, she will work with Congressman Graves in this matter.





Will update as I get more information, as it looks there is support in the right direction.


Posted Via AR15.Com Mobile

Quoted:



The way that reads to me Flamethrower is if DOD decides to install a guided dust collection system on vacuum sweepers in Aircraft Carriers, then every company manufacturing a like guided, dust collection vacuum sweeper will be subject to ITAR registration and subsequently subject to $2,250.00 registration fee. So anyone manufacturing a weapon or cartridge is subject to ITAR registration. DDTC says the same thing.


On a note of optimism. My U.S. Congressman is Sam Graves. He is one of maybe two Congressman who holds an FFL. This issue has been assigned to an aid who is not in this week. He will be in touch next week and a file has been created to work from.


NRA has a legal designate assigned to every state in the U.S.. Missouri"s designate is Liz Williams, she works lock in step with Sam Graves and his aids. She knows every person on his staff by first name it seems. I have spoken with Liz Williams, she will work with Congressman Graves in this matter.





Will update as I get more information, as it looks there is support in the right direction.


Posted Via AR15.Com Mobile

Brandon,

I have completed my application for a Type 07, they have cahsed my check and I am in waiting mode. I will keep you posted of my success.

Something was recently brought to my attention by a couple of my associates that are in the business and manufacture ammunition. Please review the following links and advise.

http://www.pmddtc.state.gov/regulations_laws/itar_official.html

http://www.pmddtc.state.gov/regulations_laws/documents/official_itar/ITAR_Part_121.pdf

http://www.pmddtc.state.gov/regulations_laws/documents/official_itar/ITAR_Part_122.pdf

Evidentally, one individual called the State Dept. andinquired about this.He was told that he must register and pay the $2,000+ fee in order to leagally manufacture ammunition for retail sales. Its very possible that the person he spoke with didnt know what they were talking about. Small business like us cant afford to pay an annual fee like that just to manufacture ammo. Some people have said that it only applies to exportand DoD contract items.

So me, as a small business with a Type 07, manufacturing ammunition for retail sales online, locally and at gun shows, am I required to register with ITAR and pay the yearly fee? Please advise, we are hesitant to proceeed until we have clarification.

Thanks in advance for your help and for the impressive service you make available to guys like me.

Hey XXX!

I would login to the member area and open the document titled License Types and read the section on potential disadvantages of an FFL07.

Thanks!
Brandon

Type 07

"Disadvantages: You have to submit an annual report to ATF on April 1st of items manufactured (even if zero), which leads to additional paperwork. The renewal price is$50 per year versus $30 per year for Type 01. The ATF does renewals every three years, so it will be $150 for Type 07 versus $90 for Type 01.

All holders of either a Type 07 or Tyoe 10 license are required to submit an ATF Form 5300.11 'Annual Firearms Manufacturing and Exportation Report'. This form must be filled out and sent to ATF by April 1st of each calendar year, even if you do not manufacture any firearms.

Major Disadvantage: If you call the US Dept. of State, they might tell you all holders of either a Type 07 or Type 10 License are required to register with them under the ITAR federal regulations with an annual fee of $2,250. This government oversight was created for military defense and exporting military weapons. The federal govt.wants to ensure our military rivals do not gain access to military technology secrets.



I personally do not pay the ITAR fee and have never registered with the Dept. of State; this has been around for over 30 years and does not appear to be enforced for a 07 FFL license unless involved in military manufacturing or exporting. My ATF agent explained to me they sent the 07 paperwork after I was approved to the Dept. of State, I have never gotten a call. I just want to make sure you are aware that there is a risk here. I have seen recent efforts to have the Fed's change the language of the ITARregulations so they are not so broad. I dont know of any 07 FFL License holders who have paid the ITAR registration fee. The 07 manufacturers where I buy most of my silencers have not paid ITAR, but it is a risk I want you to at least be aware of. My attorney and I feel my business model falls under an exception noted in number 2 and 4 below. Although, I have never formally asked the Dept. of State for an exception. This is a potential risk.



122.1 Registration Requirements.

(a) Any person who engages in the United States in the business of either manufacturing or exporting defense articles or furnishing defense services is required to register with the Office of Defense Trade Controls. Manufacturers who do not engage in exporting must nevertheless register.

(b) Exemptions. Registration is not required for:

    (1) Officers and employees of the United States Government acting in an official capacity.

    (2) Persons whose pertinent business activity is confined to the production of unclassified technical data only.

    (3) Persons all of whose manufacturing and export activities are licensed under the Atomic Energy Act of 1954, as amended.

    (4) Persons who engage only in the fabrication of articles for experimental or scientific purpose, including research and development.



Reminder- ITAR registration is not an ATF requirement to get an FFL 07 or a requirement to renew an FFL 07"