Clarifying Special (Occupational) Tax Payments per Business Activity

The Firearms Regulatory Accountability Coalition (FRAC) opposes the proposed rule because it fails to distinguish between the regulatory requirements of the Gun Control Act (GCA) and the taxation framework of the National Firearms Act (NFA). They argue that the rule allows for unlawful "excess taxation" by requiring SOT payments to be tied to GCA licenses and by failing to recognize that a single business entity with multiple licenses should only be taxed once for specific business activities.

The commenter supports the proposed rule because it clarifies that Special (Occupational) Tax (SOT) payments should be based on the type of business activity (importing, manufacturing, or dealing) rather than the number of Federal Firearms Licenses (FFL) held. They argue that this change reduces administrative friction, prevents "double-payment" for small businesses, and aligns the regulation more closely with the underlying statutory intent of the National Firearms Act.