Customs Law and Tariff Solutions
Trade attorney and actively licensed customs broker.
Expert legal counsel on customs regulations, tariff matters and trade.
Practice Areas
IEEPA Tariff Refunds
To receive IEEPA tariff refunds you must file a CAPE declaration, protest or lawsuit. With our customs brokerage and legal expertise we can assess what you are owed and take the necessary action.
News
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CAPE Phase 3 Opens Oct. 6: IEEPA Refunds on Final Entries for CIT Plaintiffs
U.S. Customs and Border Protection has informed the Court of International Trade that Phase 3 of its CAPE refund system will launch October 6, 2026, enabling reliquidation of finally liquidated entries subject to IEEPA duties. Unlike prior phases, Phase 3…
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CBP Proposes Requiring Importers to Maintain Records of Foreign Export Documentation
CBP’s September 2026 advance notice of proposed rulemaking may require importers to obtain, retain, and possibly submit foreign export declarations, invoices, and certificates their suppliers filed abroad, comparing them against U.S. entries to detect undervaluation or transshipment. This article examines the proposal’s practical challenges, legitimate reasons for discrepancies, and how importers should prepare comments before the December 1, 2026 deadline.
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CBP Voiding Importer of Record Numbers on September 18
CBP will void importer of record numbers starting September 18, 2026, if Form 5106 data—physical address, email, or phone—doesn’t belong directly to the importer, immediately blocking imports. High-risk profiles include foreign IORs, DDP sales, and drop-shipping using third-party addresses. Importers should verify data and powers of attorney now to avoid stalled shipments.
Resources
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First Sale Rule and Tariff Reduction
The First Sale Rule is a valuation method recognized by U.S. Customs and Border Protection. The rule provides for the value declared at entry to be based on the price paid for the first sale of the goods intended for export to the U.S. In other words the value can be based on the price…