IEEPA Tariff Refunds

Recovering tariffs paid under the International Emergency Economic Powers Act (IEEPA) can be complex and time-consuming. Kelley Drye helps importers navigate the process efficiently to maximize potential refunds.

Recent legal developments have created the potential for importers to recover tariffs paid under the International Emergency Economic Powers Act (IEEPA). For many companies these duties represented a significant and unexpected cost. As the refund process continues to evolve through agency guidance and court proceedings, companies must evaluate their eligibility, preserve claims, and prepare for the administrative recovery process.

Kelley Drye’s International Trade team is actively advising companies on strategies to pursue IEEPA tariff refunds. Our lawyers and trade professionals help clients assess potential recovery opportunities, develop refund strategies, and navigate the procedural pathways available through U.S. Customs and Border Protection (CBP) and the courts. This includes evaluating entry data, identifying eligible transactions, preparing required filings, and managing the overall refund process.

To support clients pursuing refunds, Kelley Drye has developed a proprietary IEEPA Refund Dashboard designed to provide clear visibility into potential recovery amounts and track refund activity.

The IEEPA Refund Dashboard provides front-office visibility and compliance support by transforming a custom ACE data report into an executive view of potential tariff refunds. It quantifies refund receivables, tracks recoveries, and automates liquidation tolling and refund reconciliation to monitor refund activity. The dashboard also calculates entry-line interest accrual based on CBP requirements and updates daily. 

Users can filter data by country of origin, manufacturer, consignee, and entry type to identify specific exposures and opportunities. The underlying data is structured to support preparation of a CBP declaration package if the agency’s proposal is accepted by the Court of International Trade. For more information or to request a demonstration of the dashboard, please contact: Jennifer McCadney (jmccadney@​kelleydrye.​com) or Carrie Owens (cowens@​kelleydrye.​com).