Filing Now Open for Non-Resident Importers (NRIs)

Recover what
the courts have
confirmed is yours.

The Supreme Court has recently ruled IEEPA tariffs unlawful. If you import goods into the US from outside the country, duties you paid are now available to be refunded, regardless of where your business is headquartered. We handle every step of the recovery process for non-resident importers, including the US-side obstacles that typically make this impossible without a local presence.

Request a Free Case Review How the refund process works →

No upfront fees. Contingency-only. We only earn when you do.

$166B
Total IEEPA duties paid — eligible for refund
330K+
Importers of record affected
<90 days
Critical filing deadline
Since 2013
Our experience in financial recovery for international businesses
Our approach
Defensible claims only ACE portal prep & filing handled for you Audit-ready records kept for every filing No US presence required
What this moment means for you

Found money.
A tight window.
One shot to file correctly.

On February 20, 2026, the U.S. Supreme Court ruled IEEPA tariffs unconstitutional. The Court of International Trade subsequently ordered U.S. Customs and Border Protection (CBP) to develop a refund mechanism. CBP's CAPE tool (Consolidated Administration and Processing of Entries) built inside ACE, went live on April 20, 2026. Filing is open now.

These are duties your business has already paid, and the court has ordered them returned. If you're a non-resident importer, the challenge is compounded: the refund process requires US banking enrollment, ACE portal access, post summary corrections, protests and documentation coordination that is difficult to navigate from outside the country. That's exactly what we help you handle.

Read the full IEEPA breakdown →
01
ACH enrollment is required, and it requires a US presence CBP no longer issues paper checks. Every refund is electronic via ACH, which means a US-enrolled bank account is a prerequisite. For non-resident importers without a domestic banking relationship, this is the first obstacle we help you clear.
02
ACE portal access is not automatic for foreign-headquartered importers Submitting your claim requires an active ACE Secure Data Portal account. The setup process involves identity verification and business documentation that can be particularly challenging for importers without US representation. We manage this process and the filing that follows.
03
Improperly filed claims carry real audit risk CBP retains the right to audit refund claims for up to five years after filing. A claim filed without proper documentation, reasonable care evidence, and a clear compliance record creates exposure that outlasts the refund itself. We build the audit trail into every filing from day one.
04
The sprint has started CAPE Phase 1 opened April 20, 2026. The filing window varies by entry type and liquidation status, and the clock on some protest windows is already running. For entries approaching the 180-day post-liquidation deadline, time is the critical variable. The preparation work that should have started weeks ago needs to happen now.
How we work

From review to refund,
done right.

01 — Review
Case Evaluation

We assess your entry data, liquidation status, and duty payment history. We don't take on claims we can't defend. If we don't believe it's recoverable, we'll tell you directly.

02 — Set Up
US-Side Prerequisites

We handle ACE portal enrollment, ACH banking coordination, post summary corrections and any US-side infrastructure your claim requires. These are the steps that typically block non-resident importers from filing on their own — we've built a process around clearing them.

03 — File
Compliant Submission

We compile all entry records, HTS classifications, and proof of payment and file your claim through the correct channel, whether ACE portal declaration, Post Summary Correction, or Protest, based on your specific entry lifecycle. Nothing is submitted until it's confirmed accurate.

04 — Recover
Refund & Audit Record

We track the liquidation and reliquidation process through to payment, calculate applicable interest, and maintain a full compliance record on file, because CBP has up to five years to revisit any claim we submit.

Why Max Customs Refund

Built for importers without a US presence.

The obstacles non-resident importers face are real. We've built our practice around removing them.

⚖

We decline indefensible claims

If we don't believe your claim is solid, we say so and explain why. We will not file something we wouldn't stand behind in front of a CBP examiner. That stance protects you, and it's exactly the discipline that we practice.

🌐

We clear the US-side roadblocks

ACH banking enrollment, ACE portal setup, and US-side documentation requirements are standard prerequisites that stop most non-resident importers before they can even begin. We've built a process specifically to handle these obstacles on your behalf, regardless of where your business is based.

📋

Audit-ready from day one

CBP has up to five years to audit any refund claim. Improperly filed claims, even honest mistakes, can result in penalties that outlast the refund itself. Every filing we make includes full documentation of reasonable care and a compliance record that holds up under scrutiny.

🏛

A track record that predates this moment

Max Customs Refund & The Max Company have operated in business financial recovery since 2013, in settlement programs, tax credits, SBA loans, lines of credit, working capital and more. We've successfully helped hundreds of US businesses with custom financial solutions.

⚡

Filing is now live

The CAPE refund portal opened April 20, 2026. ACH enrollment and ACE account access are mandatory prerequisites, importers without both cannot receive payment. We handle ACE setup and prepare your CAPE Declaration CSV for submission as part of every engagement.

🎯

Specialists in non-resident importer claims

Foreign importers who paid IEEPA duties face a layered set of challenges that domestic importers don't: no US banking relationship, no ACE account, no local representation. We've designed our engagement model specifically around these realities, so you don't need a US office to access your refund.

No cost to explore

Find out if you have a recoverable claim.

We work with importers worldwide. Tell us about your situation, we'll assess what's recoverable, explain exactly what we'll handle on the US side, and give you an honest answer about what to expect.

Request Your Free Review
IEEPA Tariff Refunds — Explained

What happened, what it means, and what non-resident importers need to do.

A guide to the Supreme Court ruling, the CBP refund process, and the specific considerations for importers whose businesses are headquartered outside the United States.

The Supreme Court ruling

On February 20, 2026, the U.S. Supreme Court issued its decision in Learning Resources, Inc. v. Trump, affirming a lower court ruling that President Trump lacked statutory authority under the International Emergency Economic Powers Act (IEEPA) to impose broad-based tariffs. The Court ruled unequivocally that IEEPA does not authorize the imposition of tariffs.

Following the ruling, the President issued an executive order halting collection of all IEEPA tariffs effective February 24, 2026. The U.S. Court of International Trade (CIT) subsequently issued orders directing CBP to liquidate or reliquidate affected entries without regard to IEEPA duties, and confirmed that all importers of record whose entries were subject to those duties are entitled to relief.

Which tariffs are covered? IEEPA tariffs paid since February 4, 2025 (the "fentanyl" tariffs on goods from China) and since April 2, 2025 (the "reciprocal" tariffs) through February 24, 2026 are eligible for refund. Section 232, Section 301, and other tariff categories are not affected by this ruling.

The four-step CBP refund process

CBP built a dedicated refund module called CAPE (Consolidated Administration and Processing of Entries) within its Automated Commercial Environment (ACE) system. The portal went live April 20, 2026. The four-step structure, as outlined by CBP and confirmed at launch:

Step 1 — Claim Filing: Importers of record submit a declaration listing entries on which IEEPA duties were paid.

Step 2 — Validation & Processing: CBP runs automated checks on formatting, completeness, and eligibility. Validated entries move into mass processing where IEEPA duties are removed and refund amounts are recalculated.

Step 3 — Liquidation: Entries proceed to liquidation or reliquidation, establishing the formal duty determination that allows refunds and applicable interest to be issued.

Step 4 — Payment: Refunds are aggregated and issued electronically via ACH. CBP no longer issues paper checks.

Update: The portal is open CBP's CAPE tool — Consolidated Administration and Processing of Entries — went live inside ACE on April 20, 2026. Phase 1 is now accepting CAPE Declarations. CBP has advised that valid refunds will generally be issued within 60–90 days of Declaration acceptance. The CIT continues to monitor progress as later phases for more complex entry categories are developed.

Why liquidation status matters critically

Your options depend heavily on where your entries are in the liquidation lifecycle:

Unliquidated entries — the most straightforward. The CIT ordered CBP to liquidate these without regard to IEEPA duties. These are covered under CAPE Phase 1, which is now open. Importers with unliquidated entries can file a CAPE Declaration now.

Non-final liquidated entries — entries where the 180-day post-liquidation protest window has not yet expired. Phase 1 covers entries within 80 days of liquidation, which falls within the broader 90-day voluntary reliquidation period. For entries between 80 and 180 days post-liquidation, the correct path is a formal Protest. If you don't act before the window closes, the liquidation becomes final.

Finally liquidated entries — where the 180-day period has passed and CBP's determination is legally binding. This category remains unresolved. The CIT's current orders do not explicitly address it, and CBP has not issued guidance. Litigation may be required for these entries.

Steps non-resident importers should take now

The refund portal is now open. Phase 1 is accepting filings. For non-resident importers, the prerequisites are more involved than for domestic filers, but each one is solvable. These steps apply immediately:

1. ACH enrollment in ACE. As of February 6, 2026, all CBP refunds are issued electronically via ACH only. This requires a US-based bank account. Importers without an existing US banking relationship will need to establish one or work through an authorized agent. This is a required prerequisite, any importer not enrolled risks having refunds rejected outright.

2. ACE portal account access. Importers who don't currently have an ACE Secure Data Portal account need to apply now. For foreign-headquartered businesses, this process involves additional identity and business verification steps. Without an active account, you cannot submit a refund claim.

3. Entry data compilation. Gather entry summaries, HTS classifications, proof of payment, and import documentation for all IEEPA-affected entries. CBP will require complete, consistent records at the time of filing.

4. Assess liquidation status. Work with your customs broker to identify each entry's current status: unliquidated, non-final, or finally liquidated. The correct refund path depends on this determination.

5. Consider protest preservation. For entries approaching the 180-day liquidation window, filing a formal Protest may be warranted to preserve your rights while administrative procedures are developed.

What about litigation?

Over 2,000 companies have filed cases before the CIT to preserve their refund rights. The government has told the CIT that filing may be necessary: "Our position is that you have to file a claim in this court." Importers who file in the "New IEEPA Tariff Cases" group are positioned to receive refunds, with interest, under CIT-approved stipulations.

The standard administrative deadlines give importers until February 3, 2027 to file suit (two years from when the first IEEPA fentanyl tariffs were paid). However, waiting risks missing interim deadlines, particularly the 180-day protest window on liquidated entries.

Our position on litigation We work with legal counsel where it is warranted. For most small and mid-size importers, the administrative ACE refund path will be the most direct route. We help you prepare for that path, identify entries that may require legal protection, and connect you with our qualified trade counsel when needed.

Recent Developments

Apr 20, 2026
CAPE portal goes live — Phase 1 filings now open for unliquidated entries and entries within 80 days of liquidation
CBP / ACE Portal
Mar 25, 2026
CBP's tariff refund ACE system could be operational by mid-April
CBP / Court Filing
Mar 12, 2026
CBP outlines four-step refund framework for 53 million entries across 330,000+ importers
U.S. Court of International Trade
Mar 6, 2026
CIT pauses immediate refund order; grants CBP 45 days to build ACE processing module
CIT — Judge Eaton
Mar 4, 2026
CIT issues Universal Refund Order: all importers of record entitled to benefit of ruling
CIT — Atmus Filtration v. U.S.
Feb 24, 2026
IEEPA tariff collection halted by executive order; effective as of today
White House
Feb 20, 2026
Supreme Court rules IEEPA tariffs unconstitutional in Learning Resources v. Trump
U.S. Supreme Court
Feb 6, 2026
CBP eliminates paper refund checks; all refunds now issued electronically via ACH
CBP
Quick reference
Feb 4, 2025
Fentanyl tariff start date (China)
Apr 2, 2025
Reciprocal tariff start date
Feb 24, 2026
Tariff collection halted
Apr 20, 2026
ACE refund portal launched
Feb 3, 2027
CIT litigation deadline (earliest)
Not sure if your entries qualify?

We work with importers worldwide. We'll review your situation, assess what's recoverable, and walk you through exactly what we'll handle on the US side, at no charge and with no obligation.

Request Free Case Review
About The Max Company

Precision Expertise.

We're a specialist practice helping non-resident importers and customs brokers recover IEEPA duties they're entitled to, through precise, compliant, professionally executed claims work that accounts for the unique obstacles of filing without a US presence. We've been providing financial solutions since 2013.

Who we are

A team of industry experts.

The Max Company has operated in business financial recovery since 2013, in settlement programs, tax credits, SBA loans, lines of credit, working capital and more. We've successfully helped hundreds of businesses with custom financial solutions across borders.

We bring that same discipline to IEEPA refunds for non-resident importers, with a straightforward promise: we will not file a claim we don't believe in, and we will not take a fee unless you receive a recovery.

Our commitments

What we stand for, in plain terms.

We only file what we'd defend

Before we engage, we evaluate your claim honestly. If we find it isn't defensible under current CBP guidance and court orders, we'll tell you that clearly. We have declined engagements, and will again. Our credibility is built on that selectivity.

Compliance is the work, not a constraint on it

There are faster paths and aggressive interpretations available in this landscape, however we don't use them. Every filing we make is structured around what CBP and the CIT have actually authorized. Getting it right matters more than getting it first.

Non-resident importers deserve the same access

Foreign importers who paid IEEPA duties are legally entitled to the same refunds as domestic ones, but the practical barriers to claiming them are substantially higher. We built our model specifically to bridge that gap, so where you're headquartered doesn't determine whether you can access what's owed to you.

We align incentives, not billing clocks

Contingency pricing means we only earn when you recover. It also means we self-select into claims we're confident in. Our fee is a percentage of what we recover, nothing else. You'll never receive an invoice before a refund arrives.

Our history

Over a decade in financial recovery.

Max Customs Refund was founded in 2013 with a straightforward goal: help businesses identify and recover money they are legitimately owed, through disciplined, documented, compliant processes.

We've worked across various private and public program recoveries and business financial solutions. The IEEPA refund moment is significant, and the complexity it presents for non-resident importers is a problem we are specifically equipped to solve.

2013
Founded The Max Company was started with a focus on business financial recovery and compliance-first methodology. Assisted with businesses filing in the Deepwater Horizon settlement.
2015
Commercial Real Estate Brokerage Expanded to assist clients with property acquisitions, financing, and investment deals alongside our growing financial recovery practice.
2020
CARES Act Assistance Added services to help small & medium-sized businesses with CARES Act and SBA loans.
2025
IEEPA Refund Practice Launched dedicated IEEPA tariff refund service for non-resident importers following the Supreme Court ruling.
Pricing

You pay nothing
until you're paid.

Our fee is a percentage of the refund we help you secure, that's it. No retainers, no hourly billing, no upfront cost. Our incentives are fully aligned with yours from the first conversation.

How our pricing works

We operate on a contingency model: our compensation is tied entirely to your recovery. If you don't receive a refund, you don't owe us anything. We charge a percentage of the recovered amount, structured to decrease as the size of your recovery increases, so larger claims benefit from a more favorable rate.

This model isn't just client-friendly, it means we only engage on claims we believe in, because we bear the cost of preparing every case we take on. That discernment protects you as much as it protects us.

Zero dollars owed until refund funds arrive.

We don't send invoices before your money arrives. The contingency fee is settled from the recovery itself, you never write us a check in advance of receiving yours.

Request a Free Case Review
Direct Claimants

Tiered Contingency Rate

For importers of record filing directly. Your rate decreases as your recovery grows, and our fee covers not just the filing, but the US-side setup required for non-resident importers to receive payment.

First tier of recovery Higher %
Mid-range recovery Stepped down
Larger recoveries Most favorable
Exact tier thresholds and rates are discussed during your free case review based on estimated recovery value. We're transparent about the math before you commit.
  • ✓ Full claim preparation and filing
  • ✓ ACE portal enrollment and setup
  • ✓ ACH banking coordination for non-US importers
  • ✓ Liquidation and protest monitoring
  • ✓ Interest calculation and documentation
  • ✓ No charge if no recovery
Customs Brokers & Partners

Referral & Co-Filing Model

For licensed customs brokers & freight forwarders working with importer clients. Preserve your client relationship while we handle the recovery work.

  • ✓ Revenue share on every client you refer
  • ✓ We take on the workload and reduce your compliance and audit risk
  • ✓ Your client relationship stays yours
  • ✓ Options range from behind-the-scenes support to complete end-to-end handling
  • ✓ Co-filing arrangements available where warranted
  • ✓ No volume minimums required
Broker arrangements are structured individually. Please contact us to learn more.
Contact us to Discuss a Broker Arrangement
Pricing questions, answered directly.
What is a contingency fee, exactly? +
A contingency fee means we charge a percentage of what we recover, not a flat retainer, not hourly billing, not an upfront deposit. If your claim results in a $0 recovery, your cost is $0. If we recover $80,000 for you, we take our agreed percentage of that $80,000. The fee is settled from the recovery itself.
Why not just charge a flat or hourly fee? +
Flat and hourly fees transfer all the risk to you. You'd pay regardless of whether the claim succeeds. Contingency pricing means we bear the preparation cost. It also means we're incentivized to take only the cases we're confident in, which protects you from a firm that files volume regardless of merit.
What does the free case review actually involve? +
A 15-30 minute consultation where we look at your entry data, assess which duties fall within the eligible IEEPA period, evaluate liquidation status, and give you an honest estimate of what's likely recoverable. We'll also tell you clearly if we don't think the claim is worth pursuing.
Do I need to share financial records with you? +
For the initial review, we need entry summary data, typically what your customs broker already has on file. CBP's ACE portal process will require entry-level records, HTS classifications, and proof of payment. We guide you through exactly what's needed and how to compile it. We do not require broader financial statements for basic refund claims.
I'm based outside the US. Can I still file for a refund? +
Yes. Non-resident importers who were the importer of record on IEEPA-affected entries are entitled to the same refunds as US-based importers. The practical barriers, ACH enrollment, ACE portal access, documentation coordination, are higher for foreign-headquartered businesses, but they are solvable. Helping you clear those barriers is specifically what we do.
Are there claims you won't take on? +
Yes. If a claim involves entries that aren't clearly within the eligible IEEPA tariff window, or where the liquidation status makes recovery uncertain without litigation we're not positioned to handle, or where the documentation isn't sufficient to support a compliant filing, we'll decline and explain why. We'd rather have a shorter client list of defensible claims than a high volume of speculative ones.
When will I receive my refund? +
CBP have officially stated it should take 60-90 days from filing. Refunds will be processed through the four-step validation and liquidation cycle. We monitor your claim's progress and keep you updated at each stage. We won't give you a date we can't guarantee, but we'll give you an honest picture of where things stand.
Get in Touch

Start with a
conversation.

Tell us about your situation, where you're based, what you imported, and roughly what you paid in duties. We'll be direct with you about whether we can help, how much we believe is recoverable, and what we'll handle on the US side. No commitment required.

What to expect

We respond to all inquiries within one business day. The initial case review is a 15-30 minute call, we review your importing history together, assess your claim, and give you a straightforward picture of what we believe is recoverable and what we'll handle on the US side on your behalf.

If we don't think we can help, we'll tell you that directly and suggest what your next step should be.

  • Response Within one business day
  • First call 15–30 minute case review
  • Cost No charge until you receive a recovery
  • Who we work with Non-resident importers of record, US importers, and licensed customs brokers worldwide
Acting quickly matters.

The ACE refund portal is now live as of April 20th, 2026. For non-resident importers, there are several steps that need to happen before a claim can be filed. The time to start that process is now.

Schedule a Call

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