What We’ve Learned Since Learning Resources: Navigating Refunds and New Tariffs Post-IEEPA
On February 20, 2026, the Supreme Court of the United States held that the International Emergency Economic Powers Act (IEEPA) does not authorize the president to impose tariffs.
The Trump administration immediately began the process of replacing IEEPA tariffs, imposing immediate temporary Section 122 tariffs and promising increased permanent tariffs under different statutes and negotiated trade agreements. Meanwhile, the question of IEEPA tariff refunds fell to the lower courts—and on March 4, the U.S. Court of International Trade ordered U.S. Customs and Border Protection to establish a process for issuing IEEPA tariff refunds on virtually all affected imports.
To help industry keep up with the rapid pace of new developments, International Trade partners Michael P. House, Ann Nagele, and Andrew Caridas discussed the refund process and the new tariff landscape, including all that had changed since their Update. Joining them was special guest Claus Zimmermann, global head of international trade at Ashurst LLP, who provided the perspectives of key trading partners on the evolving U.S. tariff regime.
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