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Posted: 8/17/2010 12:35:12 PM EDT
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I have a few questions for the hive, the ATF has given me different answers depending on who I call. Assume I am a Type 11 FFL holder, I have customers established for the following examples and storage that meets the requirements set forth by the ATF and other applicable agencies (say rented bunker space on a military installation).
1- As a licensed DD importer can I import sales/training samples of machineguns and grenade launchers? (For example LMO's AGS-17 that they use for their training courses) The use of the items would be for contracted training of .gov/.mil personnel. If not, what importers license or ATF licenses would be required? 2- When I import a DD or MG for training/sales to a Government agency, such as a 40mm grenade launcher for an LE Agency to deliver less than lethal munitions or a training sample for the military/sales sample for a LE Agency, is there a time frame in which I have to dispose of the sales/dealer sample or can it retained by the license for as long as their license is valid? 3- I import a functional tank (say T-72) for use in training a military organization for their future deployment training a foreign force. What kind of documentation is required for the import of that live gun tube to be approved? There is no sale involved but an ongoing training and sustainment program. 4- Using the same example as above, in regards to live warheads for artillery, RPG's and automatic grenade launchers, has the ATF set guidelines for their markings that do not involve engraving (for the obvious reasons)? And once I expend the round how do I verify this to the ATF? 5- In training contractor security forces on the above mentioned items and warheads, if the warheads never leave the licensee's possession, is there any tax associated with the training? I know it may sound like a silly question but the wording about transfers and such make an issue of concern. |
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Quoted:
I have a few questions for the hive, the ATF has given me different answers depending on who I call. Assume I am a Type 11 FFL holder, I have customers established for the following examples and storage that meets the requirements set forth by the ATF and other applicable agencies (say rented bunker space on a military installation). 1- As a licensed DD importer can I import sales/training samples of machineguns and grenade launchers? (For example LMO's AGS-17 that they use for their training courses) The use of the items would be for contracted training of .gov/.mil personnel. If not, what importers license or ATF licenses would be required? 2- When I import a DD or MG for training/sales to a Government agency, such as a 40mm grenade launcher for an LE Agency to deliver less than lethal munitions or a training sample for the military/sales sample for a LE Agency, is there a time frame in which I have to dispose of the sales/dealer sample or can it retained by the license for as long as their license is valid? 3- I import a functional tank (say T-72) for use in training a military organization for their future deployment training a foreign force. What kind of documentation is required for the import of that live gun tube to be approved? There is no sale involved but an ongoing training and sustainment program. 4- Using the same example as above, in regards to live warheads for artillery, RPG's and automatic grenade launchers, has the ATF set guidelines for their markings that do not involve engraving (for the obvious reasons)? And once I expend the round how do I verify this to the ATF? 5- In training contractor security forces on the above mentioned items and warheads, if the warheads never leave the licensee's possession, is there any tax associated with the training? I know it may sound like a silly question but the wording about transfers and such make an issue of concern. I'll try to answer these questions as you presented them. 1. You may not import MGs without having a Class I SOT. Remember that the DD importer FFL is just for normal Title I stuff and DDs. You still need the SOT for any other NFA. I do not know if the law allows for importation for training yet, although I know that it has been proposed. A DOD demo letter might clear the way. 2. I do not know if there is a time frame or not. Hrm. Import/export is still a really dark area for me. But I do have a licensed importer SOT friend who may have the answers. Give me some time and I'll see what I can find out. 3. See above. 4. The ATF does have an exemption for DDs where "marking" is an issue. You have to write to them for guidance. You also notify them that the item has been expended or used. 5. Transfer tax is due upon a transfer to a non-licensee, non-government entity, etc. If you're not transferring, you're okay. FET is only due when the item is sold, too. So, I think you're safe from those taxes. Mike |
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I don't know if this is a competitive situation, but Long Mountain Outfitters offers classes that run along the same lines. They may be able to answer your questions. Based on their inventory, they appear to import both DD's and other Title II.
http://www.longmountain.com/classes/ M3MAAWS 84mm recoilless (Saab Bofors Anti Armour AB) ZPU-2 twin 14.5mm KPV machine guns GP25/30 Soviet style 40mm AGS-17/30 RPG-7 RPG-18 SPG-9 120mm mortars Maljutka 122mm wire guided munitions M134 Minigun MK19 You could also IM tony_k to see if he has any other info/sources. |
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Shea does not want to help anyone set up a business competing against his. And that is exactly what I will be doing, cheaper and more in depth from instructors who have used these weapons in combat.
But luckily I found some one at ATF who was more than happy to help out and make sure I was on the right path. She revealed the big secret to all of this. As long as you have the right paperwork anything is possible. All it takes is money. |
| Thanks! We have the Instructors (when they are in country, but luckily there is no shortage of quality guys here) but the big stuff is what is the issue. The prices you can get things for are shockily reasonable. but by the time you figure in shipping costs and taxes it begins to get sobering again. T-72, under 45k. Delivered takes it up over 65k. Still a good deal but.... Not pocket change either. |
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Quoted:
Thanks! We have the Instructors (when they are in country, but luckily there is no shortage of quality guys here) but the big stuff is what is the issue. The prices you can get things for are shockily reasonable. but by the time you figure in shipping costs and taxes it begins to get sobering again. T-72, under 45k. Delivered takes it up over 65k. Still a good deal but.... Not pocket change either. Still better than the M60 tank going for 130k.... and thats without a functioning weapon system with false explosive armor... Best of luck out there Let us know if you're ever taking applications. 
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