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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The Court of International Trade Certifies an IEEPA Refund Class: What the Freestyle World Ruling Means for Importers With Outstanding Refunds
The Court of International Trade certified a nationwide class of importers who paid unlawful IEEPA tariffs, but no refund injunction has issued yet. This article explains the class definition, key exclusions like Brazil and India tariffs, interaction with CBP’s CAPE system, and whether importers should rely on the class or file individual claims before 2027 deadlines.
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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.
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…