How to Add ATF 4473 Approved Silencers Into Your Gun Trust

UPDATE: October 9th, 2026

The ATF as of October 9th, 2026 has released guidance to the public and FFL's about 4473 only silencers.  As it is now, 4473 only silencers can be added to the gun trust using the assignment sheet only.  However, if the silencer was originally transferred on a ATF Form 4/eForm 4, you would still need to use the ATF Form 4/eForm 4 to have the silencer approved in the name of the gun trust before you can use the assignment sheet to add it to your gun trust.  

But please note, The ATF also reminds everyone of the Future Risk[s] of Unregistered $0-tax Firearm[s].

This means that if the law changes, e.g. the tax stamp could increase to any amount over $0 dollars and the gun trust would be in possession of contraband, "The NFA treats unregistered firearms as contraband. Individuals who make, possess, transfer, or receive unregistered NFA firearms are subject to felony penalties and forfeitures. 26 U.S.C. §§ 5861, 5871, 5872; 49 U.S.C. §§ 80302, 80303."

The typical process to add NFA firearms and Title 1 firearms into your gun trust is to add them using the assignment sheet.  NFA firearms require an approved tax stamp in the name of the gun trust to add them to the gun trust.  Title 1 firearms owned by the settlor can be added using the assignment as needed.

But what happens when a silencer is transferred directly to an individual using an ATF Form 4473 only, without an approved ATF Form 4 or tax stamp?

Unfortunately, neither the ATF nor the DOJ has provided specific guidance addressing this situation. We don’t recommend assuming that a silencer transferred only on an ATF 4473 to an individual can be simply assigned to a gun trust using the assignment sheet like an ordinary Title 1 firearm. The ATF Form 4 / ATF eForm 4 application ties the approved ATF Form 4 to a specific individual, gun trust, or other legal entity receiving the firearm. However, the newer ATF 4473-only silencer transfers do not currently provide the same clear mechanism for changing ownership from the individual to a trust. 

For now, owners should retain their ATF Form 4473-related purchase documentation and avoid attempting to transfer ownership to their gun trust unless and until there is clear guidance from the ATF or DOJ which describes that process. We will keep updating our site with more information as it is provided by the ATF or DOJ.