Tariff Refund Program
Full-Service IEEPA Tariff Recovery for U.S. Importers
Federal Claims Advisors provides end-to-end tariff refund services — from initial entry audit through CBP protest filing, CIT litigation, and refund verification. We handle the complexity so you can focus on your business.
Every engagement starts with a free assessment to determine your eligibility, quantify your exposure, and map your deadlines.
No upfront cost for assessment. Flat-fee protests. Contingency litigation. We succeed when you recover.
What We Do for You
We manage the full recovery pathway from entry review through refund confirmation, with each phase structured to reduce delay, preserve filing rights, and keep your documentation aligned for the next step.
Audit
Pull ACE data, identify IEEPA entries, and build your complete entry universe.
Prepare
Draft the protest memo, assemble supporting records, and map every controlling deadline.
File
Submit CBP protests and, when needed, initiate CIT or Tucker Act litigation on your behalf.
Verify
Track reliquidation, confirm payment, and reconcile the refund in ACE and with your finance team.
Service Tiers
The right pathway depends on liquidation status, deadline posture, and whether court action is needed.
CBP Protest
- Entry universe audit
- Liquidation date mapping
- Protest memo drafting
- Form 19 preparation and filing
- CBP correspondence management
- Refund verification
CIT Litigation
- Everything in CBP Protest, plus:
- CIT summons and complaint filing
- Federal court representation
- Discovery and briefing
- Settlement negotiation
- Judgment enforcement
Tucker Act
- Everything in CBP Protest, plus:
- Court of Federal Claims filing
- Unlawful exaction complaint
- Jurisdictional briefing
- Settlement or trial
- 6-year statute of limitations
Who We Serve
Importers of Record
If you paid IEEPA tariffs between April 2025 and February 20, 2026, you are likely eligible for a refund. We work with importers of all sizes — from small businesses with a handful of entries to enterprises with thousands of entries across multiple ports.
The refund process is the same. The scale of the engagement adjusts to your entry universe.
Customs Brokers and Trade Teams
We partner with brokers and internal compliance teams when refund volume exceeds internal capacity. Your broker can support the ACE side; we handle protest preparation, legal memo drafting, and the litigation pathways that fall outside standard brokerage services.
Exporters and Supply Chain Partners
If your U.S. customer is the importer of record and is pursuing refunds, we can help coordinate on contractual pass-through obligations, landed-cost recalculations, and supply agreement updates for the post-IEEPA / Section 122 environment.
What Makes Us Different
Documentation-First Approach
We build the evidence file before we file anything — entry universe, payment proof, liquidation evidence, and legal memo assembled first.
Court-Admitted Counsel
Christopher Sullivan is admitted before the Court of International Trade and the Court of Federal Claims — the two courts that hear tariff refund cases.
Full-Spectrum Coverage
CBP protest, CIT litigation, and Tucker Act claims under one roof, without handoffs or gaps between stages.
Aligned Incentives
Flat fees for protests. Contingency for litigation. We succeed when you recover.
Compliance + Recovery
We address IEEPA refund recovery and Section 122 compliance advisory together, because importers often need both at the same time.
Verification to Close
We do not consider the engagement complete until the refund is verified in ACE and reconciled with your finance team.
Engagement Timeline
Timelines vary by volume, CBP processing, and litigation posture, but this is the typical progression.
| Phase | Timeframe | What Happens |
|---|---|---|
| Free Assessment | 1–2 business days | We review your entry data, identify IEEPA exposure, map deadlines, and provide a written assessment with recommended next steps. |
| Engagement & Audit | Week 1–2 | Sign engagement agreement. We pull ACE data, build the entry universe, assemble documentation, and prepare the protest package. |
| Filing | Week 2–4 | File CBP protest(s) and/or initiate CIT or Tucker Act litigation. You receive copies of all filings. |
| CBP Processing | Months 1–6 | Manage CBP correspondence, respond to requests for information, and monitor for protest allowance or denial. |
| Litigation (if needed) | Months 2–18 | Proceed in CIT or the Court of Federal Claims if CBP denies the protest or the posture warrants direct court action. |
| Refund & Verification | 30 days post-reliquidation | Confirm refund issuance in ACE and reconcile payee, date, and amount with your finance team. |
What to Have Ready
For your initial assessment, the more information you can provide, the faster we can map your situation.
Minimum Starting Point
- Entry numbers or broker statements listing them
- Approximate import date range (April 2025 through February 2026)
- Known liquidation dates or notices
- Payment proof such as broker billing, ACH confirmations, or bank statements
- Broker contact information so we can coordinate on ACE data
If You Do Not Have Everything Yet
That is fine. Start the assessment with what you have. We will tell you exactly what to gather, what can be pulled from ACE, and what should be preserved first to protect filing deadlines.
Start Your Free Assessment
No upfront cost. No obligation. We review your data, quantify your exposure, and tell you exactly what to do next.