Tariff Refund Task Force
Practical Strategies for Importers
Overview
On February 20, 2026, the United States Supreme Court struck down the tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA), ruling them unlawful in Learning Resources Inc. v. Trump. The decision invalidates the sweeping tariff regime that began in early 2025 — including the "Fentanyl Tariffs" on Canada, Mexico, and China and the "Liberation Day" reciprocal tariffs imposed on imports from virtually every country in the world. Estimates of the total tariffs collected under the now-invalidated regime range as high as $175 billion.
We recognize that our clients and companies around the world are now confronting a set of legal questions they have never faced before: whether and how to recover tariffs already paid, how to navigate a refund process that is entirely unsettled, and how to weigh the legal, financial, and political considerations that come with suing the federal government. In some cases, the amounts at stake are significant enough to implicate duties to shareholders and other stakeholders.
While the refund process is only beginning to take shape, Quinn Emanuel has already developed deep knowledge of the legal landscape to help our clients stay a step ahead. We have been advising clients on their potential refund rights since before the Supreme Court issued its decision, and our Tariff Refund Litigation Task Force stands ready to help companies assess their claims, understand their options, and pursue refunds aggressively — whether through litigation in the Court of International Trade, the CBP administrative process, or both.
Our team has substantial experience in customs, trade, and international law before the Court of International Trade, the Federal Circuit, and the Supreme Court — precisely the venues that will determine the scope and timing of any refunds. Our track record includes some of the most significant recoveries against the U.S. government in history, including the "Risk Corridors" litigation under the Affordable Care Act, which resulted in more than $12 billion in payments by the federal government.
To ensure easy access to our analysis and guidance on this rapidly developing area of law, we have created this page as a dedicated resource. Please check back regularly as we update it with client alerts, legal memoranda, links to media coverage, and other materials as developments unfold.
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