Tariff Advisory Services

IEEPA Tariff Refund Opportunity

A recent court ruling from the United States Supreme Court has created potential refund opportunities for businesses that paid tariffs under the International Emergency Economic Powers Act (IEEPA).

The U.S. Supreme Court determined that tariffs imposed under the IEEPA were not authorized—opening the door for businesses to obtain refunds of IEEPA tariffs.

WonderTrust helps businesses identify affected import entries, organize documentation, and prepare for potential tariff recovery as the federal refund process develops.

Scale of the IEEPA Tariff Refund Opportunity

Potential amount of tariffs for review

$ 0 Billion

Importers potentially affected

0 +

Import entries that could be impacted

0 Million

Government filings indicate that IEEPA tariffs may have been levied across millions of import transactions. As the federal government develops an administrative process for refunding IEEPA tariffs, businesses should review import activity and start gathering documentation in connection with determining eligibility for tariff refunds.

Recent IEEPA Tariff Refund Developments

February 20, 2026

The U.S. Supreme Court ruled that the government cannot use the IEEPA to impose global tariffs.

March 4, 2026

The Court of International Trade ordered U.S. Customs and Border Protection to remove certain IEEPA tariffs from affected import entries.

March 6, 2026

CBP advised the court that system upgrades would be required to implement refunds.

March 12, 2026

CBP submitted a proposed administrative framework for processing IEEPA tariff refunds.

March 2026

The status of import entries, including whether entries have reached final liquidation, emerged as a key factor in determining how IEEPA tariff refunds may be administered.

Additional developments are expected as the federal government continues to develop the process for reviewing import entries and issuing potential IEEPA tariff refunds.

How Might This Affect My Company?

Businesses that imported goods during the relevant period may have been impacted by IEEPA tariffs, even if they are not currently tracking those amounts.

Imported goods into the United States during the period when IEEPA tariffs were in effect
Paid tariffs that may have been imposed under IEEPA, either directly or through a customs broker
Have access to import records, customs documentation, or tariff payment data
Are unsure how much was paid in tariffs or whether your business may be impacted

How WonderTrust Helps

WonderTrust helps educate businesses on current IEEPA tariff refund developments and potential opportunities and, where appropriate, assists qualifying businesses in preparing for potential refund processes through a structured approach focused on document collection, import tariff analysis, and readiness for evolving filing requirements.

Assessment & Initial Review

Businesses complete a short assessment outlining their import activity and customs broker relationships. WonderTrust performs an initial review to identify potential areas of exposure and relevance to IEEPA tariff developments.

Advisor Consultation

A WonderTrust advisor reviews the assessment information and discusses potential IEEPA tariff considerations, including how recent developments may apply based on the company’s import profile.

Import Data Collection and Analysis

Relevant import documentation, including entry summaries, broker reports, and internal import records, is gathered and organized. These materials are reviewed to help identify potential IEEPA-related tariff exposure and support preliminary analysis.

Preparation for Refund Process

Businesses are supported in organizing documentation and preparing for potential refund processes as additional administrative guidance becomes available.

Assess Whether IEEPA Tariff Refunds May Be Available to Your Business

Businesses that imported goods during the relevant period can complete a short assessment to help evaluate whether they may have paid IEEPA tariffs that could ultimately be eligible for refunds.

CONTEXT

WonderTrust is committed to monitoring, collating, and disseminating reliable information with respect to IEEPA tariff matters.

The IEEPA tariff refund process is currently being developed by the federal government and will likely be impacted by future court rulings, administrative guidance, and/or legislation. Eligibility for and availability of IEEPA tariff refunds will be specific to each business based upon its unique facts and circumstances.

WonderTrust is not a governmental agency. We rely on experienced consultants who monitor legislative, judicial, and administrative developments relating to IEEPA tariffs.