Upper or Lower considered the "firearm"?

In your case, yes. I suspect in most cases, yes.

In what is probably a small number of cases, both might be. I have a rifle that has two different numbers on the upper and lower. This was created when the importer paired high quality uppers (but poor quality lowers) with good quality lowers (and garbage uppers). That is how it is registered, that is how it will remain. Would make verification a PITA, should it ever happen.
 
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The SCAR has the S/N on the upper so....

You can buy lowers in the US without an FFL.
 
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