IEEPA Tariff Refund Recovery

Most U.S. importers who paid IEEPA tariffs between February 2025 and February 2026 qualify if three things are true: (a) your business was listed as the importer of record on CBP Form 7501 (Box 22), (b) the duties you paid included IEEPA, Section 301, or reciprocal tariffs as separate line items on your entry summaries, and (c) at least one refund pathway is still open for those entries — CAPE Phase 1, a 19 U.S.C. § 1514 protest, or Court of International Trade litigation. We confirm all three during the free eligibility review.

We focus on importers who paid at least $1.5M in duties on goods from China, or $3M+ from other countries subject to IEEPA or reciprocal tariffs. There's no upper limit — we work with multi-billion-dollar importers as well. If you're below the minimum, CBP's CAPE portal inside ACE may be a self-service option.

You may still recover. When a carrier or freight forwarder is listed as the importer of record, they collected the refund — but they passed the tariff cost down to you in pricing. Under the legal theory of unjust enrichment, you can pursue what you actually paid: the carrier shouldn't keep a refund on duties they never absorbed. This requires a lawsuit rather than a CBP filing, and only law firms can pursue it. Our trade-counsel partners handle this pathway under the same engagement. The pool is big — roughly $125B of the $166B in IEEPA refunds went to IOR carriers who passed those costs straight through to their customers.

Per-entry deadlines, not a single date. Once an entry liquidates, the CAPE Phase 1 reliquidation window runs 80–90 days; the formal § 1514 protest window runs 180 days. Unliquidated entries have no fixed cutoff today but should be filed under CAPE Phase 1 now. Entries fully liquidated beyond the 180-day protest window have no current administrative pathway — a future CAPE Phase 2 may eventually cover them, but CBP has not published a Phase 2 timeline. CIT litigation is the only way to preserve those entries today. There is also a hard outside deadline: the government has until June 6 to appeal the underlying ruling. If they win, payouts on unfiled claims freeze.

A government win at the Federal Circuit would likely pause CAPE entirely. Claims already on file — especially protective Court of International Trade filings — preserve your rights and toll the statute of limitations even if the administrative process halts. Importers without filings of record at that point are exposed: the queue freezes and there's no clear way back in. The reason we file CAPE, PSC, protest, and CIT in parallel is so a single ruling can't freeze you out.

Customs brokers charge low fees but can only file simple CAPE Declarations; they cannot file CIT cases, pursue unjust enrichment lawsuits, or underwrite refund advances. Consulting firms typically charge 15–30% on contingency but face the same legal limits. Our trade-counsel partners are admitted to the U.S. Court of International Trade, can pursue every refund pathway (CAPE, PSC, protest, CIT, and unjust enrichment lawsuits where applicable), and qualify your claim for our financing partners' advance product. Same contingency range, far more they can actually file on your behalf.

We pursue every pathway your entries qualify for, in parallel:

• CAPE Phase 1 — CBP's ACE-based refund module for unliquidated entries and entries liquidated within the past 80–90 days under CBP's voluntary reliquidation window. Live since April 20, 2026. CBP's stated processing target is 60–90 days after an accepted Declaration.
• Post-Summary Correction (PSC) — corrects the IEEPA duty line on unliquidated entries. Must be filed within 300 days of the entry summary date and before the entry liquidates.
• CBP Protest under 19 U.S.C. § 1514 — formal protest for entries already liquidated outside the CAPE window. 180-day filing window from liquidation.
• Court of International Trade (CIT) under 28 U.S.C. § 1581 — protective litigation that preserves your rights regardless of how CAPE develops. Required if CBP denies a protest, and the only path that protects you if a Federal Circuit appeal pauses CAPE.

Filing across pathways simultaneously is the only way to be in line for whichever moves fastest.

A denial doesn't end the matter. Denied protests are escalated to the U.S. Court of International Trade — the specialist federal court for customs disputes — under 28 U.S.C. § 1581. Our trade-counsel partners maintain active CIT dockets and handle the escalation under the same contingency engagement. If you've already filed a protective CIT case, the denied protest folds into your existing position.

Once your claim is filed and underwritten, our independent third-party financing partners front a portion of your expected IEEPA refund to your business account. You repay them when CBP pays the refund. If the claim doesn't succeed, you owe nothing — the financing partners absorb the loss. Advance amounts and timing depend on claim size, entry status, and underwriting; we'll walk through specifics on your intake call.

Fully available. We handle the filing the same way — contingency only, no upfront cost, every pathway covered under one engagement. The advance is an option, not a requirement.

Zero upfront cost. Our compensation is a percentage of the refund you actually recover, paid from the refund itself. If we don't recover money, you don't pay. Specific contingency rates depend on claim size and the pathway your entries require (administrative refunds carry lower rates than litigation refunds). We walk through the engagement terms in detail before you sign anything.

Filing a refund claim does put your import history under CBP review — that's true regardless of who files it. Classification errors, valuation issues, or other compliance gaps from the 2025 tariff chaos can surface during this review. Working with trade counsel rather than a customs broker matters here: they structure your filings to minimize exposure, flag any pre-existing issues before CBP raises them, and represent you if CBP questions an entry.

No. Section 122 of the Trade Act of 1974 (19 U.S.C. § 1862) is a separate legal authority from IEEPA, and the Supreme Court ruling does not apply to it. The replacement tariffs imposed under Section 122 — currently in the 10–15% range — are in effect and are not refundable through the IEEPA refund process. Our engagement covers IEEPA-era refunds only.

The Lefkowitz Group is an asset and revenue recovery firm — not a law firm. We work with licensed customs brokers and independent trade-counsel partners who handle every legal filing and Court of International Trade representation. That separation lets us extend the contingency-plus-advance product to importers who otherwise wouldn't get that structure from a traditional law firm on hourly billing. Our trade-counsel partners are admitted to the U.S. Court of International Trade and specialize in IEEPA refund recovery.