Prepare for what's next

New and evolving tariffs have implications for businesses throughout the supply chain: increased material costs (driving up overall costs), shortages, shifts in demand. Additionally, the invalidation of the 2025 International Emergency Economic Powers Act (IEEPA) tariffs opens the door for companies to obtain refunds for tariffs paid – a complex opportunity that will require careful analyses and documentation.

How CohnReznick can help

Importers seeking refunds for additional IEEPA tariffs paid will be required to substantiate their claims, likely with analyses prepared on an item-by-item basis based on the date of each import. These analyses, in short order, can become highly detailed and complex.

With specialization in damages and refund calculations, CohnReznick can help clients quantify potential refund amounts, organize documentation for claims, and prepare analyses and reports that concisely and completely support refund requests

Separately, our teams are well-versed in the complexities of tariffs and can help boost your business and supply chain’s resilience as the landscape continues to evolve.

• Predictive modeling and analytics

• Transfer pricing

• Industry-specific guidance: Manufacturing and distribution (M&D), consumer and industrial, retail, construction, and more

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NEWS & TRENDING INSIGHTS

Supreme Court invalidates 2025 IEEPA tariffs, raising complex refund questions

On Feb. 20, 2026, the Supreme Court struck down the 2025 tariffs imposed under the IEEPA, opening the door for companies to obtain refunds for these tariffs paid.

Read about the tariff ruling and how companies can prepare to seek refunds.

Read Article

Frequently Asked Questions (FAQs)

Explore common questions about the Supreme Court’s ruling on the 2025 IEEPA tariffs, and refund potential.

  • On Friday, Feb. 20, 2026, the U.S. Supreme Court issued a landmark decision striking down the Trump Administration’s additional tariffs imposed under the International Emergency Economic Powers Act (IEEPA), and ruled that the President exceeded the authority granted under IEEPA. 
  • The Supreme Court’s ruling opens the door for companies to obtain refunds for the additional IEEPA tariffs that they paid. However, no clear process to apply for, or receive, those refunds was included in the decision – that is yet to be determined. In the absence of any special Court directive on the refund process, the preexisting tariff dispute rules will continue to apply. Accordingly, companies that want refunds will need to dispute the tariffs that they paid with the Customs and Border Protection (CBP), the federal agency that monitors imports and collects tariffs.  A federal court, the Court of International Trade (CIT), has jurisdiction to resolve tariff disputes, and, to that end, to date, thousands of companies have proactively filed complaints with that court seeking refunds, in anticipation that the Court would find the IEEPA-imposed tariffs unconstitutional.
  • Importers seeking refunds will be required to substantiate their claims.  Specifically, we anticipate that importers will need to prepare analyses that compare a) the tariffs actually paid with b) the tariffs that would have been paid in the absence of the tariff increase under IEEPA. Those analyses will likely need to be prepared on an item-by-item basis based on the date of each import. 

    These analyses, in short order, can become highly detailed and complex.

    Importers that use freight forwarders to manage their imports may need to obtain the relevant underlying import supporting documents from those companies.  Other companies’ accounting and enterprise resource planning (ERP) systems may not maintain the required data with the requisite granularity. Regardless, importers will likely need forensic accounting support and trade compliance expertise to assemble, reconcile, and validate refund calculations capable of withstanding detailed scrutiny.

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This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.