No Recovery, No Fee: How Contingency Tariff Refund Recovery Works
The Tariff Bureau operates on a pure contingency model — we take a percentage of the refund only when CBP pays you. No upfront fees, no screening charges, no retainers. If you don't recover, you owe nothing. TariffIQ™ handles the analysis and CAPE prep; your licensed broker files.
The Supreme Court’s February 20, 2026 ruling in Learning Resources v. Trump held IEEPA tariffs unlawful, opening $166 billion in refunds for 330,000 importers of record. As of June 29, 2026, $71.06 billion has been certified and sent to Treasury through CBP’s CAPE system.
Following the Learning Resources v. Trump ruling that opened $166 billion in IEEPA refunds across 330,000 importers, a pure contingency model means our fee is entirely conditional on your recovery. We take nothing if CBP does not pay. No upfront assessment fees, no hourly rates, no retainers. The Tariff Bureau's fee is a percentage of the actual refund amount received — duties plus statutory interest — paid only after CBP disburses your refund. This aligns our incentives entirely with yours: we maximize your recovery because that is how we earn our fee. The contingency model is particularly well-suited to IEEPA refund recovery because (1) the legal basis for the refund is established by Supreme Court ruling — this is not speculative litigation; (2) the CAPE system gives importers a structured recovery path; and (3) the primary variable is preparation quality and filing speed, not litigation outcome.
How the Fee Works
How Our Contingency Fee Is Structured
Our contingency fee is a percentage of the gross refund recovered — duties and statutory interest combined. The specific percentage depends on your entry volume, complexity, and recovery amount. We disclose the exact fee in your Engagement Letter before any work begins. There are no hidden fees, no setup costs, no charges if CBP rejects your Declaration for reasons outside our control, and no fee at all if you recover nothing. The fee is calculated on the gross refund amount, deducted at disbursement, and the net amount — your refund minus our fee — is wired to your designated bank account. The QBO disbursement workflow maintains a complete audit trail: Refund Disbursement Statement attached to every transaction, chain-of-custody documentation matching DOD-grade signed/verified disbursement standards.
Form 4811 Model
The Form 4811 ACH Designee Model
CBP Form 4811 — Authorization for Refund of Excessive Duty Deposits — allows an importer of record to designate a third party to receive their IEEPA refund ACH payment directly. The Tariff Bureau uses the Form 4811 model where appropriate: CBP sends the gross refund directly to our Mercury business account, we deduct our contingency fee, and wire the net amount to the client within the agreed disbursement timeline. The Form 4811 must be properly executed, signed by the IOR, and on file with CBP before the CAPE Declaration is submitted — the designee's ACH banking information must also be enrolled in ACE. Form 4811 authorization is specific to the designated entries and amounts — it does not give us any ongoing access to your ACE account or other entries.
Why Contingency Makes Sense
Why Contingency Beats the Alternatives for IEEPA Recovery
Most importers face three choices: (1) hire a trade attorney or broker at hourly rates to manage CAPE filings — costs $250–600/hour regardless of outcome; (2) attempt to file CAPE Declarations in-house — error rate is approximately 30% across submissions industry-wide per Gaia Dynamics' analysis of 300,000+ entry line items; or (3) work with a contingency advisory firm like The Tariff Bureau. For importers with significant refund exposure — typically $50,000 or more — the contingency model almost always delivers more net recovery than hourly billing, because prep quality is higher and the firm is incentivized to maximize the refund. The screening fee model is also becoming obsolete: as of mid-2026, all major IEEPA refund advisory competitors offer 100% free assessments. The Tariff Bureau's free assessment gives you a refund estimate before you commit to anything.
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Important Note: The Tariff Bureau is not a law firm and does not provide legal advice. Our contingency fee is for advisory and CAPE Declaration preparation services only. Importers with complex entry situations, CIT lawsuit questions, or prior disclosure needs should also consult qualified trade counsel.
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Find Out Where Your Entries Stand
TariffIQ™ identifies your CAPE phase position, refund estimate, and next step. Free assessment. No obligation. No recovery, no fee.
Informational only. Not legal, tax, or financial advice. The Tariff Bureau LLC is not a law firm, is not a licensed customs broker, and is not affiliated with CBP or any U.S. government agency. The IEEPA statute of limitations accrual date remains legally unsettled. Consult qualified trade counsel for your specific situation.