Tariff refund Overview as of 4.20.2026
Summary eligibility Overview:
First and foremost, the SCOTUS ruling only applies to tariffs issued under the IEEPA, and not duties levied through Sections 122 and 301 of the Trade Act and Section 232 of the Trade Expansion Act. Businesses or individuals that were importers of record on goods that had IEEPA tariffs, meaning they were the purchasers who paid the fees to bring them into the U.S. and meet the Phase 1 criteria, are eligible to apply for a refund. Alternatively, if you used a customs broker to manage the processing of importing and paying tariffs, the broker can apply for the refund on your behalf.
To apply, individuals first need to set up an account in CPB’s Automated Commercial Environment portal. From there, they can apply for refunds through what is called a CAPE Declaration, which is a Comma-Separated Values (.CSV) file with a list of up to 9,999 entries of the refunds of IEEPA duties being requested. CBP has created a reference guide, (see below link to pdf), outlining the process for filling out a CAPE Declaration. Once CBP accepts the CAPE Declaration, the agency said that individuals can expect refunds to generally be issued within 60-90 days unless a compliance concern requires further CBP review.
For businesses that have already had to scramble and adjust your operations to cover these tariffs, going through the process to recoup these duties may seem truly daunting. If you are already stretched thin running your business and want to optimize your refund, it may be worth seeking the assistance of a customs broker in this process.
Tariff refund overview process overview:
US Customs and Border Protection (CBP) has issued the much-anticipated instructions for how and when importers should submit refund requests for the emergency International Emergency Economic Powers Act (IEEPA) tariffs that were ruled invalid by the US Supreme Court. As described in more detail below, importers are directed to submit refund requests through the newly created Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment Secure Data Portal (ACE Portal). Importers should be able to begin submitting refund claims through CAPE beginning on Monday, April 20, 2026.
Overview of CAPE
CAPE is designed to consolidate refunds of IEEPA duties, including interest, rather than processing refunds on an entry-by-entry basis. This represents a significant operational improvement over traditional processing methods.
CBP plans to implement CAPE through a phased development approach, adding more functionality in subsequent phases to process refunds for more complicated entries.
Tariff refund site:
https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds
Tariff refund reference guide (pdf) ACE Portal:
Eligibility requirements
To be eligible to use CAPE, the following prerequisites apply:
- Importer of Record (IOR) and authorized customs broker must have an established ACE Portal account.
- Refund recipients must use the ACE Portal account to provide CBP with bank account information for refunds.
- Refunds will be paid electronically by Automated Clearing House (ACH), and recipients must have US bank account information designated for refunds on file with CBP.
Scope of CAPE Phase 1 refund
What is covered
In Phase 1, CAPE will process most entries that are either unliquidated or up to 80 days past their liquidation date. Following CBP review, these entries will be liquidated or reliquidated and refunds will be issued.
CAPE will also process entries with liquidation status of suspended, extended or under review, as well as warehouse and warehouse withdrawal entries.
What will not be covered in Phase 1
Entries falling into the categories below are being evaluated for future phases of CAPE and will not be accepted by CBP during Phase 1 of CAPE refunds:
- Entries that have been flagged for reconciliation, as well as Entry Type 09—Reconciliation Summary
- Entries on a drawback claim
- Entries covered by an open protest
- Entries not filed in ACE and entries without a liquidation status in ACE
- Entries subject to Antidumping/Countervailing Duties (AD/CVD), for which the Department of Commerce (DOC) has issued liquidation instructions, that are pending liquidation in accordance with 19 U.S.C. § 1504(d)
- Entries for which liquidation is final
Pursuant to the orders issued by the Court of International Trade (CIT) in refund litigation pending before the court, CBP is required to issue refunds for these entries, but these refunds will not be processed in Phase 1 due to current functional limitations of the new CAPE system.
CAPE refund process overview
Beginning April 20, 2026, IORs and customs brokers will be able to file Phase 1 requests for refunds of IEEPA duties directly through the ACE Portal by uploading a comma-separated values (CSV) file, referred to as “CAPE Declaration,” in the new CAPE tab in ACE. The CAPE tab will be available in the Importer, Organizational Broker and Filer sub-accounts in ACE.
Each individual CAPE Declaration is limited to 9,999 entries, but multiple CAPE Declarations may be submitted.
The process will be as follows:
1. The CAPE process starts with the filing of the CAPE Declaration in the ACE Portal by the IOR or the authorized broker who filed entries on behalf of the IOR.
2. ACE will conduct two series of validations: the first series checks the CAPE Declaration itself, and the second series checks the individual entries listed in the file.
3. For valid entry numbers, ACE will update the entry summary lines to remove the dutiable IEEPA Harmonized Tariff Schedule (HTS) Chapter 99 codes and duties, resulting in a new version of the entry summary. Once the IEEPA duties have been removed, ACE will recalculate the duties owed without the dutiable IEEPA HTS code(s).
4. CBP will review the updated version of the entry and liquidate or reliquidate.
CAPE Declaration format
- Format and structure: The template is an Excel spreadsheet that automatically downloads when the user clicks the “CAPE Upload Template” link in the ACE Portal. It has a single column labeled “Entry Number” in the first row (Column A), with all remaining rows left blank for data entry. When uploading, the file must be saved as a CSV file (.csv).
- What to enter: The user will need to enter the applicable entry number(s) in the first column, beginning in the second row, directly below the “Entry Number” header row.
- CBP has indicated that no information other than the entry number will be required in the CSV file.
- Entry number formatting rules: The system will validate the entries. Common validation requirements include,
- Entry numbers must be 11 alphanumeric characters. Dashes are optional, and any special characters will be stripped before the 11-character check.
- No duplicate entry numbers are permitted.
- For Filer and Organizational Broker accounts, the first three characters of the entry number must match the Filer Code of the account.
- The IOR number of the importer account must match the IOR number of the submitted entry summary.
Refund mechanics
Once a CAPE Declaration is validated and accepted, ACE will update the relevant entries to exclude IEEPA duties. Following CBP review, those entries will be liquidated or reliquidated and refunds for the IEEPA duties paid will be consolidated by IOR, or by the party the IOR has designated to receive refunds on its behalf via CBP Form 4811 (Form 4811 Special Address Notification) and liquidation date.
Refund timing
According to US Customs, importers and authorized brokers should anticipate that valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further CBP review. However, certain scenarios, such as entries that are extended, suspended or under review and warehouse entries, will maintain their liquidation status with validated refunds issued at liquidation.
Next steps
After the first phase is active, US Customs will begin updating CAPE to accept refund requests for entries not eligible for the first phase. It is not clear at this point when the next phase(s) of CAPE will be implemented, but we anticipate the processing of those claims will take longer than those during the first phase.
United States Treasury IRS electronic payment submission and refunds as of 9.30.2025
IRS new Executive Order extends the electronic payment mandate to include individual income taxes. The Executive Order is effective for tax refunds and payments as of Sept. 30, 2025.
All tax refunds will be issued electronically. You can no longer request that your tax refund be sent to you via check. All refunds will be made via direct deposit to the bank account information that you provide when filing your return.
All tax returns and quarterly estimated payments must be paid electronically. Mailing of tax return payment vouchers or quarterly estimated tax payment vouchers with checks will no longer be allowed. All payments must be made via electronic submission.
Receiving electronic tax refunds. You have likely seen the option to provide or input your bank information to receive a direct deposit of your tax refund. Alternatively, you have the option to receive your refund by check via mail. Under the new policy, you will have to provide your bank information to receive your refund via direct deposit only.
Estimated tax payments and tax return payments. If you are currently mailing in your quarterly estimated tax payment vouchers or tax return payments with a check, you will need to start making those payments electronically after Sept. 30, 2025. The IRS provides several options for making payments. More information of payment options is below.
The IRS provides several ways taxpayers – both individuals and businesses – can pay their taxes through electronic means, including:
No account set-up is needed for the following options:
- Paying directly from a bank account: Taxpayers can pay at the time they submit their return or schedule payments up to a year in advance. Individual and business taxpayers can also use IRS Direct Pay to pay taxes from their bank account. Direct Pay is free and secure, doesn’t require a sign-in, and you can change or cancel within two days of a scheduled payment.
- Using a debit card, credit card, or digital wallet: Both individual and business taxpayers can use one of these methods to pay their tax bill. However, taxpayers should be aware the card or wallet may charge a processing fee, and this option is not available for paying payroll taxes.
Account set-up is required for the following options
- Paying from an individual or business IRS account: Taxpayers who have an online account with the IRS can make payments through this account for an amount owed, a quarterly estimated tax payment, a payment on a recently filed amended return, a proposed tax assessment, a payment for an extension to file an income tax return (available January – April), an offer in compromise (OIC) application fee, or other OIC related payment.
- Via the Electronic Federal Tax Payment System (EFTPS): Taxpayers must enroll in EFTPS to make payments through this system. Taxpayers can use EFTPS to make payments from their bank accounts.
- Via an Electronic Funds Withdrawal: This option is only available to taxpayers when filing their return electronically, either using tax preparation software or with a tax professional.
For state payment-related rules, please see your particular state’s Department of Revenue website for additional guidance. This Executive Order applies to federal tax payments only.
IRS Refunds and receiving Tax Refunds Electronically
IRS payment of tax refunds via direct deposit is by far the safest and fastest way for taxpayers to receive their refunds. There are several ways for taxpayers to have the IRS deposit their tax refunds, including:
- Into a checking, savings or retirement account: Taxpayers must include their checking, savings, mutual fund or IRA account number, and the institution’s routing number on their return to enable the IRS to direct deposit their tax refund into the appropriate account. In cases where the taxpayer wants the refund deposited into a retirement account, they are responsible for informing the IRA trustee.
- Onto a prepaid debit card: Taxpayers may choose to have their refund direct deposited onto a prepaid debit card. Taxpayers will need to check with the issuing financial institution, but generally speaking, reloadable prepaid cards have account and routing numbers that taxpayers can share with the IRS.
- Onto a mobile app: Taxpayers may be able to use one of their mobile apps. The mobile app must have routing and account numbers that taxpayers can enter on a tax return. Taxpayers should check with the mobile app provider or financial institution to confirm which numbers to use.
Taxpayers Can Have Their Tax Refund Split Among Several Accounts
Taxpayers can elect to have a portion of their refund direct deposited into up to three accounts by completing IRS Form 8888, Allocation of Refund, and submitting it with their tax return. Most tax preparation software also provides this option.
Some taxpayers may encounter challenges to using the available electronic payment options. These barriers may be relatively easy to overcome by tapping into several available resources, but some taxpayers may find them insurmountable, requiring that they apply for an exception to the executive order mandate. Below are some options and resources taxpayers may consider:
- Banking Options for the Unbanked
- Unbanked individuals can find a variety of low-cost and no-cost banking options at FDIC.Gov/GetBanked.
- Recipients of Veterans Administration monetary benefits can get assistance with their banking questions at Veterans Benefits Banking Program (VBBP).
- Taxpayers Living Abroad
- U.S. citizens living overseas should explore international banking options that can accept U.S. government electronic payments.
- If your bank cannot receive U.S. Treasury deposits, you may need to work with a tax professional or contact the IRS for assistance.
At this time the IRS has not released guidance advising taxpayers about how they can apply for an exception to the Executive Order mandate, but such IRS guidance should be provided by 2025 tax return filing season
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