US Customs and Border Protection will launch a claims portal on Monday to process tariff refunds linked to recent court decisions, with potential refunds estimated at $166 billion.
Finance leaders are expected to play a central role in steering their organizations through the process, with success depending on the quality of documentation, cross-functional coordination and how companies account for eventual reimbursements.
The effort is reminiscent of pandemic-era relief programs such as the Paycheck Protection Program and the Employee Retention Credit, where CFOs served as the final checkpoint for compliance, accuracy and financial reporting, according to Bryan Graiff, who heads manufacturing and distribution at accounting and consulting firm Armanino.
“While other teams may compile the data, the CFO is ultimately responsible for ensuring its accuracy and determining the appropriate accounting treatment,” Graiff said in an interview.
The U.S. Court of International Trade issued a ruling last month requiring it to repay the tariffs struck down by the U.S. Supreme Court in February. Graiff said there is still a lingering sense of unease in the business community about the possibility of an eventual appeal by the administration.
Despite this uncertainty, Graiff said companies should not wait for final clarity before acting.
“We’re advising our customers to prepare for the opportunity to get a refund, because we think it’s going to be quite a complex process and there’s going to be a lot of work to prepare for it,” he said.
CBP’s recent efforts have given companies strong reason to hope that a viable refund process is taking shape, according to Nghi Huynh, partner in charge of transfer pricing at Armanino.
“There’s definitely some positive momentum,” he said, noting CBP’s plan to launch its portal on Monday.
Phased process
CBP is expected to introduce a phased rollout, with the agency estimating that approximately 63% of refunds will be handled in the initial phase, focused on certain unsettled entries and within 80 days of settlement.
As of April 9, about 56,497 importers had completed the steps to receive electronic refunds, representing approximately $127 billion in duties, CBP said Tuesday in a filing with the Court of International Trade.
“What changes on Monday is the launch of the claims portal itself,” Huynh said. “That’s when importers can begin to formally submit their refund requests and supporting documentation, which will allow CBP to begin reviewing and processing those requests.”
In its filing Tuesday, CBP provided an update on its consolidated administration and ticket processing program for processing reimbursement requests, saying the agency has completed “major development of all components and functionality for Phase 1 of CAPE.”
“The agency has moved to an intensive testing posture, focused on performance and scenario-based testing of all CAPE components and the correction of any defects identified during testing.” CBP officer Brandon Lord wrote in the filing.
Obstacles of documentation
The refund process is expected to require extensive documentation, including submissions from importers of record, as well as details of shipment contents and duties paid. seconds Graiff.
Companies may also need to show whether tariff costs have been absorbed internally or passed on to customers through pricing decisions at the product or storage unit level. Complexity can add up quickly, especially for large shipments containing thousands of SKUs, Graiff said.
The process could be especially difficult for businesses hit by the tariffs that deprioritized record keeping in a scramble to secure inventory.
“I saw where, in the rush to get these products, maybe some of the paperwork wasn’t always filled out 100 percent accurately,” he said.
In addition to ensuring proper documentation, CFOs should also prepare by assessing the potential “downstream impacts” of receiving a refund, such as financial reporting and tax-related issues, according to Huynh.
“For some companies, that could be a very significant dollar amount,” he said.
Graiff said close coordination of the CFO with other teams will be critical, especially with supply chain and procurement leaders closest to the underlying transactions and supplier relationships.
“They will be key in gathering the necessary documentation, with the CFO helping to ensure all inputs are aligned, accurate and ready for submission,” he said.
