Re: Benelli M4 and 922r with 7+1
922(r) is very strange and there is still a lot of debate about what is right and wrong.
From my understanding, any imported rifle/shotgun can not have more that 10 (forign made) of the following parts.
(1) Frames, receivers, receiver castings, forgings or stampings
(2) Barrels
(3) Barrel extensions
(4) Mounting blocks (trunions)
(5) Muzzle attachments
(6) Bolts
(7) Bolt carriers
(8) Operating rods
(9) Gas pistons (x2)
(10) Trigger housings
(11) Triggers
(12) Hammers
(13) Sears
(14) Disconnectors
(15) Butt stocks
(16) Pistol grips
(17) Forearms, hand guards
(18) Magazine bodies
(19) Followers
(20) Floor plates
Any imported rifle/shotgun can only be imported with one of the flowing "evil" parts.
(1) Pistol grip stock
(2) Collapsible stock
(3) High capacity magazine
So if you have a M4 (since it comes with a pistol grip stock) you can only add the magazine extention if you can swap out some of the imported parts with US made parts. Currently there aren't may options available so as of now for us parts. I dont know of more that a couple US made parts (ie forearm, magazine, follower).
There is also a big debate about how many of the 20 regulate parts are actually counted on the M4. I've seen letters from the BATF that show them counting only 11 parts all the way up to 15 parts.
My only suggestion is that you write a letter to the BATF and ask them to send you a letter with all of the parts that makes up the M4 and hope for a low part count (11-12) and then technically you would be able to legally convert it.
There is also a huge debate weither or not registering it as a SBS will negate the 922(r). I've heard both from the BATF so I'm not sure what to believe.
As you can see this topic is very confusing and there really is no easy answer.
Good luck.