Until then the existing interpretation seems to me to mainly impact occasional FFLs or hobbyists
After careful consideration, and with a little creative strategy, I think it's possible for smaller operators to conduct their affairs in a manner that would avoid triggering the registration guidelines as outlined, but if they are not so inclined, just pay the tax and move along and sleep well at night.
You said it was a hefty nut, and a government overreach but then:
Just pay the tax and sleep well at night.F.M.R.
That's how you lose it all, chief. Whatever it takes to sleep well at night...