Tax insight

IEEPA tariffs: understanding the potential outcomes ahead of the Supreme Court’s ruling

Insight
8 minute read
October 20, 2025

What happened?

Since February, the United States has imposed a series of tariffs under the International Emergency Economic Powers Act (IEEPA), in response to various national emergencies declared by President Trump. Since their imposition in February, these tariffs have affected a broad range of industries and product categories — resulting in approximately $89 billion of duties collected as of September 23 — and could reach up to $108 billion by the end of October. The US Supreme Court is reviewing a challenge that questions the legality of these measures. The outcome could retroactively impact the enforceability of IEEPA-based tariffs and trigger refund eligibility for affected importers.

Why is it relevant?

A ruling that invalidates certain IEEPA tariffs, which have raised up to $108 billion based on PwC estimates, could result in refund opportunities across affected sectors depending on the remedy the courts prescribe. Companies in high-impact industries, including electronics, automotive, industrials, and chemicals, may be entitled to reclaim duties paid since February of 2025. The case raises significant financial, operational, and compliance implications for importers who bore the cost of these tariffs, particularly those managing large volumes of entries or thin-margin goods. Refund preparation will require coordination across tax, trade, and legal teams to capture entitlements and manage risk. If refunds are permitted, it remains uncertain how laborious the process will be for importers to obtain them. The process could be complicated and cumbersome. If companies are successful in obtaining the refunds, the question will remain whether US consumers who might have ultimately borne the burden of these tariffs would see any benefit of any refunds.

Actions to consider

Companies should begin quantifying their total IEEPA tariff spend for all US import entries since February. At the same time, companies should have their legal, trade teams, and advisors monitor Supreme Court developments and assess potential refund eligibility. Proactive modeling now can help businesses prepare for various legal outcomes and enable timely action if recovery becomes available, as this may mean tens — if not hundreds — of millions of dollars for some companies. Businesses also should consider which refund mechanisms (e.g., post-summary corrections (PSC), protests, or other mechanisms ordered by court) may be viable based on the scope of the ruling.

For more details, read the full Tax Insight linked below.