As if you weren’t already giving the ATF too much information on the Form 4 (that’s the application for a tax-paid transfer of an NFA item, like a silencer) or a Form 1 (the application to make and register an NFA item), the ATF has just added a brand new section to the paperwork that allows you to pay by credit card. Previously applicants to the ATF needed to submit their $200 tax fee either with a check or money order when filing using paper copies. But this latest change adds the same ability to put that $200 tax on your AmEx that electronic Form 1 filers have been enjoying for about a year now. The new forms are already available online, and I’ve just used the new Form 4 on a Dead Air Armament Sandman silencer that arrived for me at my FFL. There’s just one wrinkle . . .
“I am paying the making tax for the applicant.” That’s the statement you make when charging your credit card. If you are indeed the applicant then there’s no issues, since you are paying for yourself. But for some gun trust lawyers, the idea that you (an individual) are certifying to be paying the registration fee for a trust or corporation (that is not you, legally speaking) might be a bit of a sticky wicket.
The gun trust lawyer who wrote up the trusts for me, Tyler Kee, and even El Jefe RF doesn’t seem to think that this is an issue: included in his packet of documents is something called a “three way contribution” document, which acknowledges that someone else paid for the registration fee for the trust out of their own pocket yet the item itself belongs to the trust. So, no worries there. Still, consult your local lawyer. As always.