IEEPA Tariff Refunds: Legal Developments and Strategic Considerations

Following the U.S. Supreme Court’s decision holding that the President lacked authority under the International Emergency Economic Powers Act (IEEPA) to impose broad tariffs on imports, Arnold & Porter has launched a multidisciplinary Tariff Refund Task Force to assist companies evaluating potential refund opportunities and related strategic considerations. The ruling invalidates approximately $160 billion to $175 billion in duties collected under IEEPA and reshapes the legal framework governing executive tariff authority.

For many companies, the tariffs at issue involved substantial payments that directly affected margins, pricing decisions, and supply chain planning. Although the Court resolved the legality of the tariffs, it did not prescribe a uniform mechanism for addressing duties previously paid. Companies affected by IEEPA tariffs — including those imposed on imports from China, Mexico, Canada, and the April 2025 reciprocal tariffs — must now navigate complex questions involving potential recovery pathways, litigation posture, administrative processes, and evolving government responses.

Arnold & Porter’s Task Force is actively advising clients across industries on assessing tariff exposure, preserving and advancing potential recovery claims, and developing strategies aligned with business objectives and risk tolerance. Strategic evaluation at an early stage can help preserve flexibility as the post-decision landscape continues to develop. The ruling also carries broader implications for the scope of executive trade authority and future tariff actions, making careful planning essential.

Below, you will find our latest insights, client advisories, and webinar programming addressing the implications of the Supreme Court’s decision and potential tariff recovery strategies. We will continue to update this page as developments unfold.

To discuss your company’s exposure or potential next steps, please contact your Arnold & Porter relationship partner or a member of our Tariff Refund Task Force.