The Supreme Court Ruled in Your Favor. Do You Know What You're Owed?
Trump's tariffs are being refunded.
In February 2026, the U.S. Supreme Court ruled 6-3 that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unlawful, finding that the authority used to impose them did not extend to tariff-setting. The Court of International Trade (CIT) subsequently ordered U.S. Customs and Border Protection (CBP) to refund all duties collected under that authority — an estimated $166 billion paid across more than 53 million import entries by over 330,000 businesses — all of whom may now be eligible for Trump tariff refund recovery.
CBP has acknowledged that its existing systems cannot process refunds at this scale through standard liquidation procedures. In response, it is developing new automated refund functionality — the Consolidated Administration and Processing of Entries (CAPE) system.
While clarity on the process is due to be announced in April 2026, importers should not assume that refunds will arrive automatically, in full, or without action on their part.
For businesses that import through a single customs broker with a complete and current Automated Commercial Environment (ACE) account, the process may be relatively straightforward once CAPE is operational. For most others, it will not be.
When Refunds Become Difficult
Common situations across mid-market importers significantly complicate the standard refund path and increase the risk that eligible duties are missed, understated, or not recovered at all.
Many businesses import goods through more than one customs broker across different product lines, ports, or trading relationships. Entry data sits across multiple accounts with no consolidated view of total IEEPA exposure. Without aggregation across all entries, an incomplete claim is the likely result — and there will be no notification that funds have been missed.
Refunds are payable only to the entity named as Importer of Record on the original customs entry. Where goods were shipped under Delivered Duty Paid terms, where a freight forwarder's embedded brokerage filed the entry, or where multiple entities within a corporate group were involved, the IOR on record may not be the business that absorbed the tariff cost.
Businesses that absorbed IEEPA tariff costs through supplier pricing adjustments, inter-company arrangements, or cost-plus contracts — but were not themselves the Importer of Record — face a different recovery path entirely. These situations require analysis of contract terms, invoice documentation, and supply chain structure to determine the most appropriate route.
For goods imported from China, IEEPA duties frequently ran alongside Section 301 tariffs, Section 232 duties, and in some cases antidumping or countervailing charges. Many online calculators do not account for these stacking complexities and may treat your total tariff burden as fully recoverable. Only the IEEPA-specific portion — identifiable by Chapter 99 HTS codes — qualifies for a refund. Working from an overstated figure can distort financial projections well before any recovery arrives.
For internationally based businesses and non-resident importers, ACE portal access requirements and the mandatory use of a US bank account enrolled in CBP's Automated Clearing House (ACH) electronic payment system can leave an approved refund in held status — earning no interest — until payment routing is resolved.
Built for exactly this moment—IEEPA refund recovery.
Founded in 1993, TTM has built an established track record in reclaiming tax paid in error — serving more than 1,100 companies across four continents and recovering millions of dollars in overpaid taxes on their behalf.
In 2026, the firm relaunched with a refined focus: assisting businesses worldwide with Trump tariff refund recovery following the Supreme Court's IEEPA ruling. The opportunity is unprecedented — and the window to act is narrow.
Learn more about our servicesAbout TTM International
TTM International is a specialist tax recovery firm with over 30 years of experience identifying and reclaiming overpaid taxes on behalf of businesses across the globe.
Unlike large advisory firms, tax recovery is all we do. Every engagement is managed directly and personally, with fee arrangements tailored to the scope and circumstances of each client.
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