Glossary
Key terms and definitions used throughout this analysis.
IEEPA(International Emergency Economic Powers Act)▾
A 1977 federal statute that grants the President broad authority to regulate economic transactions during a declared national emergency. The Supreme Court ruled on Feb 20, 2026 that IEEPA does not authorize the imposition of tariffs.
Importer of Record▾
The entity legally responsible for ensuring imported goods comply with U.S. regulations and for paying all applicable duties and fees. This is typically the party that files the refund claim.
Liquidation▾
The final computation of duties owed on an import entry by CBP. Once an entry is 'liquidated,' the duty amount is finalized. Unliquidated entries are easier to correct; liquidated entries require a formal protest or lawsuit to change.
Unliquidated Entry▾
An import entry where CBP has not yet finalized the duty amount. These have the strongest refund path because the importer can file a Post-Summary Correction (PSC) to zero out IEEPA duties before liquidation occurs.
Protest (19 USC §1514)▾
A formal administrative challenge filed with CBP within 180 days of liquidation. If an importer believes duties were incorrectly assessed, a timely protest preserves the right to a refund. Missing this window can be fatal to recovery.
28 USC §1581(i)▾
A provision granting the Court of International Trade (CIT) jurisdiction over civil actions arising from trade laws when no other specific remedy is available. Many importers filed 1581(i) actions to preserve their right to IEEPA refunds.
Court of International Trade (CIT)▾
A specialized federal court in New York City with exclusive jurisdiction over civil actions arising from customs and international trade laws. The Supreme Court remanded the IEEPA tariff case to the CIT to determine the refund remedy.
Post-Summary Correction (PSC)▾
A mechanism in CBP's ACE system that allows importers to correct entry data — including duty amounts — before liquidation. For unliquidated IEEPA entries, PSC is the fastest path to a refund.
ACE (Automated Commercial Environment)▾
CBP's primary system for processing imports, exports, and related data. Refund corrections for unliquidated entries are processed through ACE.
Cost of Capital▾
The rate of return required to make an investment worthwhile. In the context of this calculator, it represents the discount rate applied to future refund payments to determine their present value. Higher cost of capital = future payments are worth less today.
NPV (Net Present Value)▾
The value of a future payment in today's dollars, adjusted for the time value of money. A $100M refund received in 3 years at 20% cost of capital is worth about $58M today.
Expected Value (EV)▾
The probability-weighted average outcome across all scenarios. Each scenario's NPV is multiplied by its probability, and the results are summed. This is the 'fair value' of the claim given current uncertainty.
Section 122 (Trade Act of 1974)▾
Grants the President authority to impose temporary tariffs (up to 15% for 150 days) to address large trade deficits. Trump invoked Section 122 on Feb 20, 2026 as a replacement for struck-down IEEPA tariffs. These are prospective — they don't affect past IEEPA refund claims.
Section 301 (Trade Act of 1974)▾
Authorizes the U.S. Trade Representative to investigate and respond to unfair foreign trade practices. Section 301 investigations were initiated on Feb 20, 2026 for country-specific tariffs. Like Section 122, this authority is prospective only.
Section 232 (Trade Expansion Act of 1962)▾
Authorizes tariffs on imports that threaten national security (e.g., steel and aluminum tariffs). Section 232 tariffs were NOT struck down by the SCOTUS ruling — they remain in effect under separate legal authority.
Sovereign Immunity▾
The legal doctrine that the government cannot be sued without its consent. A potential (though unlikely) defense the government could raise to block refund claims. Courts generally reject this defense when the government collected money illegally.
Judgment Fund▾
A permanent, indefinite appropriation administered by the Treasury Department to pay judgments and settlements against the United States. Could be a funding source for refunds, but its use at the scale of $175B is untested.
19 USC §1505▾
The statute that provides for interest on refunded customs duties. This means importers may receive not just the principal refund but also accumulated interest — a meaningful upside not included in the base model calculations.
Remand▾
When a higher court sends a case back to a lower court for further proceedings. The Supreme Court remanded the IEEPA case to the CIT, meaning the CIT must now determine the specific remedy (i.e., how and when refunds are processed).
Liberation Day Tariffs▾
Informal name for the sweeping reciprocal tariffs imposed by the Trump administration on April 2, 2025 under IEEPA authority. These tariffs, along with all other IEEPA tariffs, were struck down by the Feb 20, 2026 SCOTUS ruling.