IEEPA Tariff Refunds: What Accounting Firms Need to Do Before April 20

Summary

• Supreme Court struck down IEEPA tariffs in Learning Resources v. Trump (February 20, 2026) — duties paid on covered imports are now refundable
• CBP's CAPE refund system launches April 20, 2026 — missing the registration deadline means Phase 1 claims are rejected
• Over $166 billion in eligible refunds across 330,000+ importers; only 8% had registered as of late March 2026
• Three steps for accounting firms: identify importer clients, confirm ACE portal enrollment, help organize entry documentation

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What Happened and Why It Matters

On February 20, 2026, the Supreme Court issued its ruling in Learning Resources v. Trump: tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceed the President's statutory authority under that law. The ruling is not limited to the plaintiff — it applies to all IEEPA-based tariffs that were in effect.

The immediate consequence: every importer that paid duties under IEEPA tariff orders has a legal right to a refund of those duties.

The practical consequence: CBP is managing the refund process through CAPE (Customs Automated Payment Engine), a new system that launches April 20, 2026. Importers must register in the CAPE system to file claims. The Phase 1 window — covering unliquidated entries and entries liquidated within 80 days of the ruling — closes with the April 20 registration deadline.

Only 8% of eligible importers had registered as of late March 2026. Over $166 billion in refunds are unclaimed.

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Who Is Eligible

IEEPA tariff refunds apply to importers who paid duties under tariff orders issued under IEEPA authority. This covers a wider range of businesses than the term "importer" typically suggests in common usage.

Directly eligible:

• Manufacturing companies that import raw materials or components
• Retailers and distributors that import finished goods for resale
• Businesses that import equipment, technology hardware, or industrial supplies

Often overlooked:

• Professional services firms that import technology hardware (server equipment, specialized devices)
• Construction companies that import materials from covered countries
• Restaurants and food businesses importing food products from covered geographies

The practical test: does the business pay customs duties anywhere on its financial statements? Freight line items sometimes embed duty costs. Many business owners who don't identify as "importers" have paid IEEPA tariffs and are eligible for refunds.

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Three Steps for Accounting Firms Before April 20

Step 1: Identify Your Importer Clients

Go through your client list and look for freight charges, import duties, customs fees, or international supply chain costs on their financial statements. These are the clients with potential IEEPA tariff refund eligibility.

Do not rely on clients self-identifying as importers — many businesses that pay customs duties think of themselves as retailers, distributors, or manufacturers, not importers. The financial statement is the authoritative source.

For any client with customs duty payments in 2024 or 2025, flag them for immediate outreach before April 20.

Step 2: Confirm ACE Portal Enrollment and Banking Details

The ACE (Automated Commercial Environment) portal is CBP's primary system for importer registration and document submission. To receive refunds through CAPE, an importer must:

1. Be enrolled in ACE with an active Importer of Record number
2. Have current, accurate ACH banking details on file in ACE

Many importers have ACE enrollments from years ago with outdated banking information. An importer who registered in ACE in 2018 and changed banks since then will not receive refund payments unless they update their ACH details before the refund processing begins.

Accounting firm action: Help your importer clients log into the ACE portal, confirm enrollment status, and update banking details. This is not a technical customs filing — it is a straightforward administrative step that most business owners can complete in 15–30 minutes with guidance.

Step 3: Help Organize Entry Documentation

CAPE will require documentation to process claims. The key data points:

• Entry numbers — the CBP-assigned number for each import entry (on the CBP Form 7501 or equivalent)
• Entry dates — when each import entry was filed
• Ports of entry — where each shipment entered the US
• Duty amounts — the tariff duties paid on each entry

This documentation is typically held by the importer's customs broker and appears in summary form on the CBP Form 7501. Accounting firms can help clients gather and organize this data, verify it against financial records, and prepare it in the format CAPE will require.

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The Advisory Conversation to Have This Week

The firms that call their importer clients this week — before April 20, before the CAPE system launches — will be the advisors those clients remember.

The framing: "We noticed [freight costs / customs duty line items / international supply chain costs] in your financials. The Supreme Court's February ruling on IEEPA tariffs may entitle you to a refund of those duties. CBP is launching a claims system on April 20. We want to make sure you don't miss the registration deadline."

This is not a technical customs advisory — accounting firms should not provide customs law opinions or file customs entries. The role is: identify the exposure, advise the client to contact their customs broker for legal compliance review, and help gather the financial documentation that the customs broker will need.

The clients who get this call and successfully register by April 20 will associate that outcome with their CPA firm. The clients who miss the deadline because nobody told them will eventually find out they missed it — and they will remember who their accountant was at the time.

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Related Reading

• AI Tariff Advisory for Accounting and Consulting Firms — Comprehensive guide to building tariff advisory services with AI workflow support
• AI Accounting Task Automation: What Small Firms Should Automate First — How to use AI to accelerate client analysis and documentation workflows
• AI Bookkeeping and Pricing Strategy for Accounting Firms — How AI changes accounting firm economics and pricing

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Sources

• Learning Resources v. Trump, Supreme Court, February 20, 2026
• CBP: CAPE (Customs Automated Payment Engine) system announcement and documentation, April 2026
• CBP: IEEPA tariff refund eligibility guidance, March–April 2026

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The Crossing Report covers the AI transition for professional services firm owners. The premium tier includes an IEEPA tariff refund client outreach kit — talking points, ACE enrollment checklist, and entry documentation request template. Subscribe here →