FL
AZ
Frost Law AZ, LLC
| ⚖︎ Furdock & Foglia Law LLP
In partnership with Blue Atlas (PCIF)
IEEPA Tariff Refund Claims

The Supreme Court ruled IEEPA tariffs were unlawfully imposed and collected.

We preserve your rights to these funds, prepare the documentation to substantiate your claim, and pursue every dollar you're owed. Contingency-based. No upfront cost.

IEEPA Tariffs Collected
$166 Billion

The Supreme Court struck down all IEEPA tariffs on February 20, 2026. ~330,000 importers are in line for refunds. Most don't know how to recover it — and each entry has its own 180-day window.

Representation provided by Frost Law AZ, LLC and Furdock & Foglia Law LLP.

End-to-End Service

Every step from initial claim through litigation, remedy phase representation, and defense against refund offsets.

1 ACE Portal & ACH Registration
2 Cross-Broker Entry Reconciliation
3 Tariff Stacking & Isolation Analysis
4 Refund Computation & Interest Calculation
5 Audit File & Documentation Package
6 Compliance & Risk Assessment
7 Liquidation Event Monitoring
8 Protest & Deadline Management
9 ACE Declaration & Refund Submission
10 CIT Complaint Filing & Litigation
11 Remedy Phase Representation
12 Defense Against Refund Offsets

Do you qualify? Tier 1 vs Tier 2

The tier determines how your refund claim is pursued. Not sure which you are? Submit anyway — the attorneys confirm during the call.

1

Tier 1 — Importer of Record

You're the legal importer on CBP customs paperwork and paid IEEPA duties directly. First in line for CBP refunds.

You're likely Tier 1 if...
  • You use a customs broker to clear imports
  • You file CBP entry summaries (7501s)
  • You have an ACE Portal account
  • You receive commercial freight (LCL / FCL ocean, air freight forwarders)
  • You import $1.5M+ annually (especially from China) or $3M+ from other countries
2

Tier 2 — Secondary claim

You didn't file CBP paperwork directly, but you absorbed IEEPA costs through your supply chain. Slower and harder to recover, but still worth pursuing.

You're likely Tier 2 if...
  • Goods arrive via FedEx, UPS, or DHL with no customs broker
  • You buy from a U.S. supplier who imports on your behalf
  • Invoices show IEEPA duty as a pass-through line item
  • Shipping surcharges reference tariff costs
  • You can identify the Importer of Record who handled your goods

The Team Behind Every Engagement

Trade Attorneys
Licensed Customs Brokers
Certified Public Accountants
Tax Attorneys
What most firms don't do
Remedy Phase Representation

Frost Law AZ doesn't just file and wait. Our attorneys represent clients in the remanded court proceedings, advocating for streamlined refund processes, nationwide injunctions, and stipulated judgments that accelerate recovery.

A risk most importers don't know about
Defense Against Refund Offsets

The government may attempt to reduce or eliminate IEEPA refunds by "offsetting" them against new tariff liabilities under Section 122 or Section 301. We actively defend clients against these offset attempts to protect the full refund amount.

Why compliance review matters

CBP will scrutinize every refund submission. Before we file any claim, our team conducts a compliance review to make sure the claim is filed correctly and nothing in the underlying data raises serious issues. This step protects the client's recovery and ensures the firm stands behind every claim it submits.

Entry Data Red Flags

Reviewing the underlying entry data for issues that could trigger a CBP audit or jeopardize the claim.

Classification and Valuation Consistency

Checking for inconsistencies in HTS codes, declared values, or country of origin reporting.

Documentation Gaps

Confirming the client's records are sufficient to support the filing and won't stall or derail the process.

Filing Confidence

The firm does not submit claims it hasn't reviewed. If something raises a serious concern, it's addressed before anything goes to CBP.

Ready to review your refund claim?

Submit a brief intake, then book a call with a trade attorney in the same session. Contingency-based — no upfront cost.

Start a refund review

Typical minimum: $3M+ annual imports ($1.5M+ from China). Tier 2 secondary claims reviewed case by case.