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As I indicated above, the ATF classifies trusts as "other business entities" so the obligation applies to trusts regardless as to whether the particular trust is acting as a true business entity (in non-ATF speak).  See for example, question 2 on ATF Form 1 (box 2). 


But you are correct that trusts have been and continue to be used as business entities.  For example, in the 19th and early 20th Century, the railroads and oil companies were mostly organized as trusts, and that's why federal anti-monopoly law is called "antitrust".


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