I use an LLC (perpetual) for my NFA stuff.  Very different than a Trust, of course.  The perpetual LLC exists only for holding NFA items, it does not generate any income, revenue, debt, etc - and my state does not require annual tax filings for it because of that.

I know Trusts required proof that a firearm was part of the trust before the rule went into effect to be able to file a tax-free Form 1 for a firearm.  However, LLC's like mine don't have any property statements or the like.  

Has anyone in this situation submitted a tax-free Form 1 for their LLC/Corp?   If so, has it been approved?

You should be the first and let everyone know how it goes. We need folks like you who think outside the box to help spreads the information others need.

I can't believe that I'd be the first...  AZ has some corp laws that make it maintenance-free to use a corp, so I went that route in the early 2000's before the NFA "trust boom" happened.

I was asking because I figured there'd be at least someone else who tried this, or who knew if there were some restrictions around it, and there isn't time for me to try it as an LLC, get rejected and then try it again as an individual.

Can I file two eForm 1's for the same NFA item - one as an individual and one as an LLC?  I don't think that would fly...  maybe it would though, since for these tax-free form 1's, neither me as the individual nor my LLC is the "manufacturer"...

I suspect the ATF is going to treat it like a Trust from the proof of ownership standpoint. The filing for a Trust or LLC are the same in the eForms site, and the requirement for proof of ownership prior to 31 January was just as unusual for normal operation of a Trust as it would be for an LLC. Normally, when you file a Form 1 under a Trust, the ATF doesn’t require an Assignment document to prove that you’ve transferred ownership of the base firearm into the Trust.

Also of note, many Trusts don’t require that the Assignment be notarized, yet the ATF (which has previously taken the position that it has no say in Trust law; a state matter) seems to be requiring a notarized assignment for this specific case when filed after 31 January.

I think I might just submit my tax-free Form 1's for my braced pistols as an individual first, then a week later, submit a second Form 1 for each of them for the LLC.  That way, the individual ones will get approved and if the LLC ones get rejected, oh well - they are approved as an individual.  If they LLC's get approved; great - that's what I originally wanted.  Other than double the effort to submit them all and overall blatant unconstitutionality of having to do any of it, am I missing anything in this plan?

i was batch denied roughly 4-25-23 for 11 trust traps. 5-13-23 i was batch approved for 14 trust traps. this might turn into some fuckery in your example. create some sort of "property statement" (whatever an llc version of assignment page is called) just for this single use, once approved it shouldn't ever be needed again. my assignment page in florida and based on how my trust is written only needed signed by a trustee, and witnessed by two people. single dimension fuckery is far easier than quadruple dimension fuckery. these are just a couple hundred dudes checking boxes on a list for millions of people, if at the end one of the boxes isnt check it fails. the contents of the box doesn't seem to matter. it's easier to sell an xbox box with 7 pounds of cat shit than it is to sell an empty xbox box. you're milage may vary.

This is what I would do.

If you submit as individual and LLC for the same firearm you're asking for trouble.

See what constitutes a bill of sale in your state, and check for any trust assignment pages utilized within your state. Then basically do a hybrid of the 2. Notarization is not required, but if you had it notarized that wouldn't hurt.

The date listed for acquisition by the LLC has to be 1/30/23 or earlier.