Unwinding IEEPA Tariffs: A Primer On Refunds

As many companies are exploring how to pursue refunds after the Supreme Court concluded that the International Emergency Economic Powers Act (IEEPA) does not confer authority on the President to impose tariffs, Ballard Spahr Partners Brendan K. Collins and Lorene Boudreau prepared a brief webinar recording sharing practical steps companies can take now to evaluate and document refund claims.

The program covers:

• What the Court of International Trade (CIT) has ordered so far regarding liquidation and reliquidation and the practical uncertainties that remain.

• What Customs and Border Protection has indicated about a potential administrative refund process (including the possibility of an ACE-based process and a timeline that “could be ready in 45 days”).

• Practical steps companies can take now, including entry-level detail gathering with supply chain teams, brokers, and suppliers.

• Key considerations for companies that reimbursed suppliers and importers of record indirectly and the related contracting and downstream customer issues.

This program was recorded on March 9, 2026, and though the area is changing rapidly, the issues to consider and recommended diligence should not. If you require counsel on pursuing a refund, or the potential for adverse trade action affecting your company, please contact Brendan Collins, Lorene Boudreau, or another Ballard Spahr lawyer.

Click here to view the program