Are you [bleep] serious?
So, your premise is that the occasional FFL or hobbyist can just go on the sly with creative strategy to avoid triggering guidelines? That's Democrat thinking right there.....
The "interpretation" is tantamount to turning a screw, so when asked by someone in the office here to mount a scope and bore sight it as a favor, I'm screwed - whether I accept a beer or not.
Hell, when someone gets a gun bequeathed to them and they ask me to strip it down and clean it for them, its pretty much accurizing it according to the interpretation and subject to the rule
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...
Taking statements out of context is not an accurate way to represent a position, you have to read and understand the entire premise.
But I'll try to clear up a few points.
I agree with you in that I clearly stated several times that I think the DDTC opinion could be, and should be, challenged legally, and there are several points that I can see where that could be done. That would require the efforts of a firm that had the resources to do that.
Perhaps an entity like the NRA seems a logical choice...but then the NRA might have to consider moving this matter along instead of just using it to solicit donations from their members.
My point is that manufacturers are already in compliance, and I see no legal action was taken by them when the fees were $250...paying the registration fee was a lot cheaper for them than fighting the requirement.
Now they are $2250 and I still see no legal challenge forthcoming...
Next year they could be $22,250...then what...?
Since firearms manufacturers are essentially competitors, I don't see a unified effort forthcoming from their direction.
So while I agree with you about that, No, I am not suggesting that smaller gunsmiths attempt to run their business "on the sly".
My comment was that the DDTC letter represents their interpretation, and my statement is an encouragement for IT&D, and all gunsmiths, to stay in business until this matter can be more clearly defined.
I'm not going to delve into the legal issues any deeper than that right now, as I think they are too specific to discuss on an open forum at this point in time.
But I did suggest two different courses of action that would enable gunsmiths to stay in business. However they choose to do that, yes, they are entitled to sleep well at night if that is important to them.
But finally...
He requested that everyone concerned research the applicability of ITAR registration to manufacturers and gunsmiths noting inconsistency and ambiguity.
And that would be exactly what I did.
It seems to me that if someone really doesn't want other folks to look at an issue and offer their opinions on the matter they might want to consider not asking for those opinions in the first place.
Just a thought.