The IEEPA Refund Opportunity and Customs Processing Reality The International Emergency Economic Powers Act (IEEPA) has been employed multiple times by recent administrations to impose emergency tariffs on imported goods. Companies that paid duties on goods covered by IEEPA tariffs may be eligible for refunds as policy changes, legal challenges, or new administrations modify these…

Introduction: A Paradigm Shift in Trade Litigation The landscape of US trade policy litigation has undergone a dramatic transformation. What began as isolated challenges to tariff authority has evolved into a massive coordinated legal campaign involving over 1,800 companies seeking to recover billions in duties paid under now-invalid tariffs. This unprecedented wave of litigation represents…

The Supreme Court Settled One Question; The CIT Must Answer Others The Supreme Court’s decision on tariff refunds established a foundational principle: importers are owed refunds for duties collected under the International Emergency Economic Powers Act (IEEPA). However, settling the legal principle of refund eligibility does not resolve the practical complexities of execution. The Court…

The Refund Uncertainty: CBP’s Position on Interest and Individual Review Following the Court of International Trade’s ruling that IEEPA tariffs are unlawful, importers assumed that refund processing would be relatively straightforward: CBP would calculate the difference between duties paid under IEEPA and duties owed under applicable tariff schedules, and refund the difference. However, recent interactions…
The Executive Order Terminating IEEPA Ad Valorem Duties: Full Scope and Limitations An Executive Order has terminated all International Emergency Economic Powers Act (IEEPA) ad valorem duties across the full spectrum of earlier orders targeting China, Mexico, Canada, Venezuela, Brazil, Russia, Cuba, and Iran. This represents a complete elimination of IEEPA-based tariff measures that had…
Sell-side tariff preparation for target companies preparing for sale. Compliance cleanup, refund opportunity capture, audit posture.
Quality of Earnings (QofE) schedules and tariff costs. EBITDA adjustments, run-rate tariff modeling, deal valuation impact.
PE portfolio tariff review across multiple companies. Standardized assessment, opportunity identification, value creation.
Comprehensive Trump tariffs 2026 overview. Section 122, IEEPA aftermath, Section 232 sectoral expansions, USMCA review.
Reciprocal tariff consultant. Mirror-tariff scheme analysis, scenario modeling, country-specific exposure.