What Every Multinational Should Know About … Preserving the Right to IEEPA Tariff Refunds (Updated with FAQs) - Foley & Lardner LLP

January 22, 2026 · General · View source ↗

A recent publication from Foley & Lardner LLP, titled "What Every Multinational Should Know About … Preserving the Right to IEEPA Tariff Refunds (Updated with FAQs)," highlights a critical area for importers and trade compliance professionals. Published on January 22, 2026, this guidance emphasizes the importance of understanding and actively preserving the ability to claim refunds for tariffs imposed under the International Emergency Economic Powers Act (IEEPA).

Multinational companies, particularly those involved in importing goods into the United States, are directly affected. Any business that has paid or continues to pay tariffs levied under the authority of IEEPA should pay close attention to the recommendations in the full article. The focus is on proactive measures to ensure that, should a legal or policy change allow for tariff refunds, companies have properly maintained their right to claim them.

While the provided summary does not detail specific tariff rates or the exact dates of the tariffs in question, the article's title clearly points to tariffs imposed under the International Emergency Economic Powers Act (IEEPA). These tariffs are typically enacted under presidential authority in response to national emergencies or threats to national security or the economy. Importers should refer to the full Foley & Lardner LLP publication for specific guidance on which tariffs and periods are relevant to preserving refund rights.

To preserve their right to potential IEEPA tariff refunds, importers and trade compliance officers are advised to:

Review Import Records: Carefully examine all import documentation and entries where IEEPA-based tariffs were paid.
Understand Tariff Basis: Confirm the legal authority under which specific tariffs were assessed on their imported goods.
Monitor Legal Developments: Stay informed about ongoing legal challenges or policy changes related to IEEPA tariffs.
Consult the Full Article: Refer to the updated Foley & Lardner LLP article, especially its included Frequently Asked Questions (FAQs), for detailed steps and considerations specific to preserving refund claims.