building suppressors: f1 vs. sot questions

Yes, it can be legal to make a silencer. For everything Form-1, from silencer designs that are easily made, to filing forms with the BATF, to 3D modeling. Remember, you must have an approved BATF Form-1 to make a silencer. All NFA laws apply.

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oct0gen
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building suppressors: f1 vs. sot questions

Post by oct0gen »

ive been getting ready to f1 my first silencer. it would be for a .22 and i have a basic and proven design that i have the tooling to manufacture. while designing i came up with a few other ideas that i would like to try. it would require the manufacture of several test suppressors in several variations. some would be tested to destruction. the problem is i would quickly rack up $200 fees on f1s and it would seem to be cheaper to just go the sot route. i have some ?s about doing this.

1. if i understand it correctly, with the sot, i can make as many suppressors as i want tax free. if i give up the sot, can i just xfer any suppressors i want to keep to myself on a f4?

2. i know the atf frowns on ffls for "personal" use. as an sot, would i need to sell a min # of units, have a storefront etc.? im not sure i want to get into to the supressor business full time. this is more a labor of love.

3. do i need a manufacturer ffl in addition to the nfa sot?

4. a manufactureer sot can build, buy, and sell, whereas a dealer sot can only buy and sell items, correct?

5. is it possible to pair up with an sot in the area and have them register the suppressors with thier co. and i would be a manufacturing subcontractor? completed suppressors would be tested and stored with the sot.
David Hineline
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Re: building suppressors: f1 vs. sot questions

Post by David Hineline »

oct0gen wrote:ive been getting ready to f1 my first silencer. it would be for a .22 and i have a basic and proven design that i have the tooling to manufacture. while designing i came up with a few other ideas that i would like to try. it would require the manufacture of several test suppressors in several variations. some would be tested to destruction. the problem is i would quickly rack up $200 fees on f1s and it would seem to be cheaper to just go the sot route. i have some ?s about doing this.

1. if i understand it correctly, with the sot, i can make as many suppressors as i want tax free. if i give up the sot, can i just xfer any suppressors i want to keep to myself on a f4?

Depends upon your situation. the SOT only adds the NFA writer onto the FFL dealers or FFL manuf. license a dealers license with SOT allows you to build nothing tax free. With the FFL SOT dealer or manuf. if you drop your license and are a sole proprietor you just keep your inventory except for post sample LEonly machineguns. If your ffl/sot is a corporation or partnership then yes you would form 4 them to yourself tax paid.

2. i know the atf frowns on ffls for "personal" use. as an sot, would i need to sell a min # of units, have a storefront etc.? im not sure i want to get into to the supressor business full time. this is more a labor of love.

It's against the law to get a FFL for personal collection, law based nothing to do with frowning. No minimum sales requred you must just do it for profit. If your business plan need 10yrs of R+D before you goto market then so be it. Storefront only required if your local zoning laws require it. If you do this from home then IRS says you must show a profit 3 years of ever 5, if you do this from commercial property IRS says you can loose a milliion dollars a year forever just like the Airline Industry.

3. do i need a manufacturer ffl in addition to the nfa sot? No you need the SOT in addition to the manuf FFL-07 the FFL-07 is the only thing that is subject to approval, once you have that the SOT is automatic with the fee

4. a manufactureer sot can build, buy, and sell, whereas a dealer sot can only buy and sell items, correct?

Correct

5. is it possible to pair up with an sot in the area and have them register the suppressors with thier co. and i would be a manufacturing subcontractor? completed suppressors would be tested and stored with the sot.
It would be easier to get yourself listed on the FFL license as a responsible person, then you would be able to possess any assets/inventory of the FFL business. Just like a Glock Salesman who travels with post sample Glock Machineguns, they are not licensed.
NFA shooters blow their load with only one pull of the trigger.
oct0gen
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Post by oct0gen »

thanks! that answered alot of my questions. i think your last statement would be the easiest for me if i can find a willing participant. anyway, i appreciate the response.
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Mtdew
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Re: building suppressors: f1 vs. sot questions

Post by Mtdew »

David Hineline wrote: It would be easier to get yourself listed on the FFL license as a responsible person, then you would be able to possess any assets/inventory of the FFL business. Just like a Glock Salesman who travels with post sample Glock Machineguns, they are not licensed.
Could you please elaborate on this. how does the ffl holder go about adding a individual to the License. It makes perfect sense but this is the first i've ever heard the basis of how a individual is allowed to carry the company's products. I figured it had to be something similar.
David Hineline
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It's just part of the process

Post by David Hineline »

It's just part of the licensing process every FFL goes through, responsible persons listed on the license. If you add/remove people you just ammend the license.
NFA shooters blow their load with only one pull of the trigger.
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Mtdew
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Post by Mtdew »

I would assume then, thats how people go to subgun matches with "company" guns. very intersting. I always wanted to know how that worked
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