CFO Guide: Model and Recover Your IEEPA Tariff Refund

The Supreme Court’s ruling in Learning Resources v. Trump established the legal basis for these refunds. IEEPA tariff refunds are not a regulatory matter delegated to trade compliance — they are a balance sheet event. For importers with significant China, Vietnam, Taiwan, or Southeast Asia sourcing, IEEPA duty payments during March 2025 through February 24, 2026 likely represent a material receivable. Under 19 U.S.C. § 1505, CBP owes statutory interest on late refunds — accruing from the date duties were paid. Every month of delay reduces your total recovery. The earlier your CAPE Declaration is filed and validated, the higher your queue position and the more interest you collect. For a company with significant IEEPA duty exposure, filing sooner rather than later meaningfully increases the interest component of your total recovery — model your specific exposure rather than relying on an industry-wide average, since accrual depends on your own entries’ duty payment dates.

For 330,000+ importers eligible for refunds, TariffIQ™ generates a structured financial model via the ACE Secure Data Portal entry data, covering: (1) Gross duty recovery — the aggregate IEEPA duty amount paid across all eligible entries, identified by Chapter 99 HTS codes on your entry summaries. (2) Statutory interest — calculated per entry based on duty payment date, current Treasury statutory interest rate, and estimated disbursement timeline. (3) Net recovery after contingency fee — your actual cash receipt after The Tariff Bureau’s contingency fee is deducted. (4) Timeline scenarios — best-case, base-case, and conservative-case disbursement timelines based on CBP processing velocity and your entry volume. (5) Phase 3 risk exposure — if you have finally liquidated entries, CAPE Phase 3 is now open; the model identifies your Phase 3 entries and the applicable filing path. The model is delivered as a structured financial summary before you sign the Engagement Letter.

For financial reporting purposes, confirmed CAPE Declaration submissions create a refund receivable once CBP validates the entries. The appropriate accounting treatment depends on your auditor’s judgment on probability of collection and timing, but the key reference points are: (1) CAPE Phase 1 and Phase 2 refunds are being disbursed — the Supreme Court’s ruling on the underlying tariffs’ unlawfulness is final; (2) CAPE Phase 3 is now open as of October 2026, covering finally liquidated entries per the July 17, 2026 CIT order and CBP’s September 15, 2026 CIT filing — model Phase 3 exposure using your confirmed filing dates and consult trade counsel for your specific entries; (3) CBP’s most recent public status update (data as of August 21, 2026) confirms $106.6 billion has been sent to Treasury for disbursement, with $132.5 billion accepted into CAPE overall. The Tariff Bureau’s Refund Disbursement Statement provides a complete chain-of-custody audit trail per disbursement — gross refund received (via CBP Form 4811 ACH designee where applicable), contingency fee deducted, net wired to client — designed to attach directly to your QBO or ERP transaction record.

Phase 3 / finally-liquidated-entry status: Phase 1 and Phase 2 refunds are live and disbursing. CAPE Phase 3 is now open as of October 2026 per the July 17, 2026 CIT order and CBP’s September 15, 2026 CIT filing. If you have finally liquidated entries, consult trade counsel about filing options and timeline. The statute-of-limitations accrual date is legally unsettled (see disclaimer below); under the more commonly cited interpretation — two years from the date duties were collected — the earliest deadlines begin arriving in early 2027 for the first IEEPA duties paid, so don’t wait on a final answer to that legal question before evaluating your options. Validation failure risk: CBP’s periodic CIT status declarations have consistently shown a significant share of submitted entries failing entry-level validation for reasons like incomplete Chapter 99 HTS codes or mismatched duty amounts. CAPE Declarations cannot be amended once accepted — errors require a new Declaration and delay your queue position. TariffIQ™ pre-validates every entry before submission. Phase 3 timing: While Phase 3 is now open, processing timelines for finally liquidated entries may differ from Phase 1 and Phase 2 — model Phase 3 separately from Phases 1 and 2 in your financial projections. CBP audit risk: CAPE submissions reopen historical entries to CBP scrutiny. Ensure entry-level accuracy before filing — incorrect valuation or classification could trigger audit exposure that offsets refund recovery.