Contrary to popular belief, the TOTAL REVENUE for both SOT fees (what FFLs pay to deal with Title II firearms) and ALL transfer and making taxes paid for 2016 was $68,614,000 according to an official report released early in 2017. Thats also extremely high, and was only that high because people with trusts/corps opted to compress their next several years worth of buying into the first ~6 months of 2016.
The same figure for 2015 was $37,879,000.
The same figure for 2014 was $27,515,000.
The same figure for 2013 was $22,476,000.
The same figure for 2012 was $16,442,000.
The same figure for 2011 was $12,582,000.
The same figure for 2010 was $9,309,000.
Also, to be clear, thats the ENTIRE revenue for ALL Title II-related paperwork (both annual dealer SOT payments that will largely continue uninterrupted, and ALL tax payments for both transfer and making of ALL types of Title II firearms.
In short, if firearm mufflers were to be transferred from Title II to Title I, and to be regulated like we regulate long guns, the TOTAL IMPACT on NFA branch revenue would be significantly less than $70,000,000. Thats an amount of money that means absolutely nothing to our government.
Further, the idea that revenues would fall is likely fallacious for another reason: Regulating firearm mufflers as long guns would subject them to Pittman-Robertson taxes, at around 10-11%.
As it stands, the entire silencer industry has retail revenues of around $100,000,000-200,000,000; If we were to move them from Title II to Title II, that market would IMMEDIATELY expand to a significant degree. Even if only expanded to $700,000,000, the Pittman-Robertson act taxes would MORE than make up the differences in federal revenues.
TLDR: Once you account for the salaries of BATFE personnel tasked with handling Title II paperwork, the entire NFA process becomes either a financial wash, or an outright loss. It is NOT a moneymaker. Regulating Firearm Mufflers like long guns would instead subject them to a different tax that would require almost zero effort for the government to collect, which in turn would significantly alter the balance and make it a net earner for the government The HPA, even with the refund provision intact, would be revenue neutral for the government within 1-3 years, and would be extremely profitable for the foreseeable future thereafter.
I thought it worth sharing.