NEWS & TRENDING INSIGHTS
Webinar: Tariff Refunds after IEEPA
Recent developments surrounding the International Emergency Economic Powers Act (IEEPA) have introduced new uncertainty – and potential opportunity – for importers impacted by tariffs.
Learn what the Supreme Court’s invalidation of IEEPA means in practice, how U.S. Customs and Border Protection (CBP) is implementing a new refund process, and the financial, operational, and accounting considerations importers should be evaluating now.
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.
Additionally, 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
• Industry-specific guidance: manufacturing and distribution (M&D), consumer and industrial, retail, construction, and more
“Companies facing distress cannot rely on tariff elimination or refunds to stabilize cash flow. Liquidity planning must account for other paths.”
“The companies that fare best will be those that can reforecast quickly, document rigorously, and build flexibility into sourcing and contracts.”
“Importers will likely need forensic accounting support and trade compliance expertise to assemble and validate refund calculations.”
Frequently Asked Questions (FAQs)
Explore common questions about the IEEPA tariff refund process.
On April 20, Customs and Border Protection (CBP) launched the first phase of tariff refunds using its new Consolidated Administration and Processing of Entries (CAPE) functionality within the Automated Commercial Environment (ACE). Under Phase 1, Importers of Record (IORs) and Customs brokers can now file CAPE Declarations for certain unliquidated entries and certain entries within 80 days of liquidation.
A CAPE Declaration consists of a list of entries for which refunds of IEEPA duties are being requested. Declarations must be filed as Comma-Separated Values (.CSV) files, each limited to 9,999 entries; multiple declarations can be filed.
CBP will calculate the refund amount, representing the difference between the tariffs paid and the amount that would have been due absent the IEEPA tariffs, then will process the resulting refunds.CBP states (Opens a new window): “Importers and authorized brokers should anticipate that valid IEEPA refunds will generally be issued within 60 - 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further CBP review. However, certain scenarios, such as entries that are extended, suspended or under review, and warehouse entries, will maintain their liquidation status with validated refunds issued at liquidation.”
Importers who need liquidity or do not want to wait for a refund have the option to sell their refund claim to a “claims buyer.” Before selling any IEEPA tariff refund, companies should carefully consider their unique financial circumstances.
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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.