The IEEPA Tariff Refund Program is real — but recovering what you're owed requires more than a portal submission. Here's what separates importers who recover in full from those who leave money on the table.
Powered by Thompson Coburn LLP — Already Litigating IEEPA Cases at the Court of International Trade
Your broker can submit entries through CBP's CAPE portal — but that's where their role ends. Ultimate legal responsibility rests with you as the importer of record. A broker files paperwork. An attorney protects your legal rights, evaluates all recovery pathways, and can litigate if CBP denies or delays your claim. Brokers cannot file suit in the Court of International Trade.
More common than most importers realize — and it creates a situation requiring far more than a broker can handle. Misclassified goods may mean overpaid duties (a refund opportunity) or underpaid duties (a compliance liability). A broker can amend filings going forward, but cannot protect what's already on the record.
Attorney-client privilege is critical here. When an attorney reviews your entry history and HTS classifications, that analysis is legally protected. Communications with your broker are NOT privileged — they can be subpoenaed. Legal counsel puts a protected wall around your compliance review before any government inquiry begins.
Clients choose between two fee structures. Option 1: an upfront flat fee covering Thompson Coburn filing a formal CBP protest, initiating CIT litigation, and setting up your ACE portal (mandatory to receive any refund) — with a contingency applied only on funds recovered. Option 2: a full contingency-only arrangement at 30–35%, with no upfront cost — the attorney absorbs all risk.
Either path gives you access to elite trade counsel at terms unavailable to a single importer walking in alone. Pricing details and the right structure for your situation are discussed during your consultation.
This is exactly where legal counsel becomes essential. Importers should engage trade counsel for entries liquidated beyond the 180-day protest period. A broker has no recourse here — but a trade attorney can evaluate litigation-based pathways through the Court of International Trade that may still preserve your claim.
This is a live risk. It remains uncertain whether the government will appeal the CIT's broad order to the U.S. Court of Appeals for the Federal Circuit. An engaged trade attorney tracks developments in real time and adjusts your strategy accordingly. A broker cannot.
Yes — and most importers don't see this coming. A wave of class action lawsuits is targeting companies that passed IEEPA tariff costs to consumers and are now claiming refunds. If that describes your business, you may face consumer litigation. A broker cannot evaluate that risk. An attorney can — under privilege.
Routine claims, maybe. Complex or high-value claims, no. CBP warned the CIT it faces an unprecedented volume of refunds its existing systems are not suited to handle. When the system stalls, denies, or flags your claim, you need someone who can respond legally — not just resubmit a spreadsheet.
Almost certainly. The IEEPA refund is often just the entry point. Once engaged, we conduct a broader review of available programs — including Section 45L, Kwong v. US IRS Penalty Refunds (hard July 10, 2026 deadline), and ERC Residual Claims (amended filings still eligible at the IRS).
We exist to close the gap between what you're owed and what you actually recover.
Complete our 2-minute eligibility assessment. We review your import history against all 233 qualifying HTS codes and tell you exactly what you may be owed.
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