U.S. $166 billion in tariff refunds kick in April 20th! How much can Chinese sellers get back? How to get it?
Published: 2026-04-17
In February 2026, the U.S. Supreme Court ruled 6-3 that theThe tariffs imposed by the Trump administration under IEEPA are beyond the authority of the President and are unlawfully imposed.
What kind of concept is that?
touch upon (a topic)53 millionCustoms records
override330,000 homesImporters
Total refunds$166 billion(approximately 1.13 trillion yuan)
This is the largest tariff refund operation in the history of the U.S. On April 20, CBP officially began refunds.
But here's the rub - as a Chinese cross-border seller, theWill you get this money?
The answer depends on your trade model. Some sellers get the full amount back, others don't get a dime.
Today's post helps you figure out three things:Why are you getting a tax refund? To whom? How do you get it?
01 A History-Changing Ruling on Why the IEEPA Tariffs Are Unconstitutional
event timeline
timing
event
2018-2025
The Trump administration has imposed tariffs on global imports under IEEPA, including “fentanyl tariffs” and “reciprocal tariffs.”
February 20, 2026
The U.S. Supreme Court ruled 6-3 that IEEPA does not authorize the President to impose tariffs, theultra vires and illegal
March 2026
Court of International Trade clarifies: tariffs imposed must be refunded, possibly with interest compensation
Does IEEPA authorize the President to impose tariffs?
❌ Not authorized. the word “tariffs” never appears in the original IEEPA text and is only used for asset freezes, sanctions, etc.
Does the President have the authority to unilaterally impose tariffs?
❌ No power. The power to collect tariffs is an exclusive power granted to Congress by the Constitution
What about tariffs already collected?
“Illegal taxes shall be refunded”.Must be returned to the importer
💡 popular understandingIEEPA was supposed to be a tool for the President to freeze foreign assets in “national emergencies,” and Trump has used it as a panacea for tariff increases, the Supreme Court has said...This key won't open this door.
02 Who does the $166 billion refund to? Get a key concept first
Refunded to: “Importer of Record” (IOR) only
This is the most crucial point:Tax refunds are only given to the company that bears the responsibility for the duty in the customs declaration - IOR (Importer of Record).
trade pattern
Who's IOR?
Who gets the refund?
Chinese sellers set up subsidiaries in the U.S., and the subsidiaries declared for importation
U.S. Subsidiary
✅ Subsidiary gets full refund
FOB/CIF terms, U.S. Customs clearance by the customer
U.S. Customers
✅ American customers get refunds, you don't.
DDP/mDDP model, you are responsible for customs clearance and tax payment
You (or your customs broker)
⚠️ Depends on the subject of the customs declaration
“Double clearing and tax inclusive” model, freight forwarder/clearance house customs clearance
Freight Forwarder/Customs Clearance
⚠️ Funding attribution is in dispute
current stateMany Chinese sellers use DDP or “Double Clearance Tax Package” mode, the main body of the customs declaration is the freight forwarder or customs clearance company, the tax refund may be directly refunded to the freight forwarder, and you do not know.
Feel free to contact customer service with questions (microsoft:: qcygscszk.cell phone:: 18676749275)
03 Three trade models, three refund paths
Path 1: Have a subsidiary/affiliate in the U.S. (best path)✅
Reconciling historical customs declarations to match IEEPA tariffs
Sifting through 53 million records
4
Automated processing of refunds by the CAPE system
Expected to arrive in 60-90 days
5
Capital flows back to China
Profit distribution/capital increase/repayment of shareholder loans
Estimated size of refunds:: Assume your U.S. subsidiary's 2024-2025 imports are $5 million and the IEEPA tariff rate is 20%:
sports event
sum of money
Total imports
$5,000,000
IEEPA duties paid (20%)
$1,000,000
Refunds can be requested
Approx. $1,000,000
Possible interest compensation
another item on the list
💡 A single subsidiary gets back million dollar refunds, which is no small amount.
Path 2: FOB/CIF terms, U.S. customers are IOR (core path) ⚠️
Your American customers get refunds, but you canConsultative sharingThe
be tactful
concrete approach
intended effect
Assisting clients in applying for tax refunds
Provide trade documents and customs records to reduce customer application costs
In exchange for price discounts or better terms
Refund Sharing Agreements
Signing a written agreement with the customer on the percentage of refund allocation prior to application
Typically available for 30%-50%
Offsetting future orders
Offsetting refunds against the purchase price of a customer's next order
Binding long-term cooperation
key chip: Clients applying for tax refunds on their own need to organize a lot of documents. If you can provide complete trade records and customs declaration information, you will have the capital to negotiate.
Path 3: DDP/“double clearing and taxation” model (difficult path)❌
This is the most headache-inducing situation:
difficulty
clarification
You're not the subject of the customs declaration.
The forwarder/clearance house is IOR and refunds are made directly to them
You probably didn't know about the tax refund.
The forwarder won't tell you.
Complexity of legal relationships
The forwarder thinks they are IOR and the refund goes to them; you think the tariffs are ultimately your responsibility
High cost of defending rights
You need to prove that you're the actual tariff payer.
Possible action::
Immediately contact the freight forwarder/clearance house to inquire if there is any record of tax refund under IEEPA
Sort through historical customs documents to find proof that you are actually liable for customs duties (payment records, invoices, etc.)
Negotiate the distribution of refunds, and if the forwarder has received a refund, request a pro rata return
Consult an attorney if necessary to pursue legal recourse
04 April 20 Refunds kick in, 5 things you must do now
serial number
act
Deadline urgency
Applicable objects
1
Confirm your IOR status: Find out who is the subject of the customs declaration
Register for a U.S. bank account: Tax refunds are only credited to U.S. accounts
🔴 Extreme urgency
Sellers who already have an ACE account
4
Contact U.S. Customers/Freight Forwarders: Refund negotiations initiated
🟡 Important
FOB/CIF/DDP Sellers
5
Sorting out customs declaration data: Matching tariff records under IEEPA
🟡 Important
All Sellers
⚠️ special attention: RefundsIt's not automatic.! You must register with the ACE/CAPE system and submit a declaration or you will not receive a refund. There are still a lot of companies on the fence, and some SMEs have given up due to the complexity of the process -It's like giving money away.The
05 What happens after the refund? Where the new tariff policy goes
Just because the IEEPA tariffs were ruled unconstitutional doesn't mean the tariffs are gone. The Trump administration is using other legal frameworks to re-impose the tariffs:
Policy tools
element
state of affairs
Article 122 Customs duties
10% added to global goods, valid for 150 days
🔴 Due July 24th
Section 301 investigations
A new round of investigations covering 16 trading partners, including China, the European Union and Japan
🟡 Activated
tariffs on China
Trump states 145% tax rate will “drop significantly, but not to zero”
🟡 Under negotiation
Canada-Mexico tariffs
30-day suspension in exchange for border control cooperation
🟡 Temporary suspension
core judgement::
✅ IEEPA tariffs retired, but new tariffs on the way
✅ Section 122 may be renewed through Section 301 when it expires in July
✅ The probability is that the 145% tax rate on China will be lowered, but it will not go to zero
⚠️ Refunds are “past” money, compliance is “future” money!
06 No Corporate America? The single most important thing you should be doing right now
Refunds are subject to you having a compliant subject in the U.S. -US Company + EIN + US Bank AccountThe
If you don't have a U.S. company right now:
You want to do it.
What's needed
processing time
Application for IEEPA Tariff Refund
U.S. Company + EIN + U.S. Bank Account + ACE Registration
4-8 weeks
Preparing for future tariff compliance
U.S. Corporation + Sales Tax Registration + Tax Representation
2-4 weeks
Reducing Supply Chain Costs of Tariffs on China
U.S. Company + Overseas Warehouse + Localized Operation
4-8 weeks
📞 The $166 billion dollar rebate cake is up for grabs. Whether you're trying to recover overpaid tariffs from the past or prepare for compliance with future tariff policies, the first step is to have a compliant U.S. corporate entity.(microsoft:: qcygscszk.cell phone:: 18676749275)
Provided by Enterprise Caiying GroupAmerican, Singaporean, Japanese, Thai, Malaysian, Canadian, Mexican, Brazilian, British, French, New Zealand, Vietnamese, Indonesian, Filipino, Dubai, etc.Foreign Company RegistrationThe company also provides the related industrial and commercial finance and taxation services; also provides Hong Kong company, Shenzhen company, Guangzhou company, Shanghai company, Hangzhou company, Beijing company, Hainan company, etc.Domestic Company RegistrationCorporate Services. Company annual audit, bookkeeping and tax reporting, payment of MPF, change of information, bank account opening, ODI filing, BVI registration, tax compliance, cross-border e-commerce accompanied by the agency operation, etc.One-stop service for enterprises. Feel free to drop me anytime you need or are interested.
Tags:
U.S. Tariff Refunds
US tariffs
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