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U.S. Customs and Border Protection is set to launch<\/a> a claims portal Monday to process tariff refunds tied to recent court rulings, with potential repayments totaling an estimated $166 billion<\/a>.<\/span><\/span><\/span><\/p>\n Finance leaders are expected to play a central role in steering their organizations through the process, with success hinging on documentation quality, cross-functional coordination and how companies account for any eventual refunds.<\/span><\/span><\/span><\/p>\n The effort is reminiscent of pandemic-era relief programs such as the Paycheck Protection Program and Employee Retention Credit, where CFOs served as the final checkpoint for compliance, accuracy and financial reporting, according to Bryan Graiff, who leads manufacturing and distribution for accounting and consulting firm Armanino.<\/span><\/span><\/span><\/p>\n \u201cWhile other teams may gather the data, the CFO is ultimately responsible for ensuring its accuracy and determining the proper accounting treatment,\u201d Graiff said in an interview.<\/span><\/span><\/span><\/p>\n The U.S. Court of International Trade issued a ruling<\/a>\u00a0last month finding that tariffs struck down by the U.S. Supreme Court in February must be refunded. Graiff said there is still a lingering sense of unease in the trade community over the possibility of an eventual appeal by the administration.<\/span><\/span><\/span><\/p>\n Despite that uncertainty, Graiff said companies should not wait for final clarity before acting.<\/span><\/span><\/span><\/p>\n \u201cWe\u2019re advising our clients to prepare for the opportunity to get a refund, because we think it\u2019s going to be a pretty complex process, and there\u2019s going to be a lot of work to do to prepare for that,\u201d he said.<\/span><\/span><\/span><\/p>\n Recent efforts at CBP have given companies strong reason to hope that a viable refund process is taking shape, according to Nghi Huynh, partner-in-charge of transfer pricing at Armanino.<\/span><\/span><\/span><\/p>\n \u201cThere is definitely positive momentum,\u201d she said, pointing to CBP\u2019s plan to launch its portal Monday.<\/span><\/span><\/span><\/p>\n CBP is expected to introduce a phased rollout, with the agency estimating that roughly 63% of refunds will be handled in the initial stage, focused on certain unliquidated entries and those within 80 days of liquidation.<\/p>\n As of April 9, about 56,497 importers had completed steps to receive electronic refunds, representing roughly $127 billion in duties, CBP said Tuesday<\/a> in a filing before the Court of International Trade.<\/span><\/span><\/span><\/p>\n \u201cWhat changes on Monday is the launch of the claims portal itself,\u201d Huynh said. \u201cThat\u2019s when importers can begin formally submitting their refund claims and supporting documentation, which will allow CBP to start reviewing and processing those requests.\u201d <\/span><\/span><\/span><\/p>\n In its Tuesday filing, CBP <\/span><\/span><\/span>provided an update on its Consolidated Administration and Processing of Entries program for processing refund claims, saying the agency has completed \u201cthe primary development of all components and functionalities for CAPE Phase 1.\u201d<\/p>\n \u201cThe agency has transitioned to an intensive testing posture, focused on performance and scenario-based testing of all CAPE components and the remediation of any defects identified during testing,\u201d\u00a0CBP <\/span><\/span><\/span>official Brandon Lord wrote in the filing.<\/p>\n The refund process is expected to require extensive documentation, including importer-of-record filings, as well as details on shipment contents and duties paid,\u00a0according to Graiff<\/span>.<\/span><\/span><\/span><\/p>\n Companies may also need to show whether tariff costs were absorbed internally or passed on to customers through pricing decisions at the product or stock-keeping-unit level. The complexity can escalate quickly, particularly for large shipments containing thousands of SKUs,\u00a0Graiff\u00a0said.<\/span><\/span><\/span><\/span><\/span><\/p>\n The process could get particularly challenging for tariff-impacted companies that deprioritized record-keeping in a scramble to secure inventory.<\/p>\n \u201cI could see where,\u00a0in a rush to get those products, maybe some of the paperwork wasn’t always filled out 100% accurately,\u201d he said.<\/span><\/span><\/span><\/p>\n Besides ensuring proper documentation, CFOs should also prepare by assessing potential \u201cdownstream impacts\u201d of receiving a refund, such as financial reporting and tax-related issues, according to Huynh.<\/span><\/span><\/span><\/p>\n \u201cFor some companies, this could be a very sizable dollar amount,\u201d she said.<\/span><\/span><\/span><\/p>\n Graiff said close CFO coordination with other teams will be critical, especially supply chain and procurement leaders who are closest to the underlying transactions and supplier relationships. <\/span><\/span><\/span><\/p>\n \u201cThey\u2019ll be key in pulling together the necessary documentation, with the CFO helping ensure all inputs are aligned, accurate, and ready for submission,\u201d he said.<\/span><\/span><\/span><\/p>\n<\/p><\/div>\nPhased process<\/span><\/span><\/span><\/h3>\n
Documentation hurdles<\/h3>\n