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Demystifying IEEPA recovery: Streamlining the CBP’s CAPE submission process

Obtaining refunds efficiently without losing sight of risk.

Following the U.S. Supreme Court’s ruling that tariffs collected under the International Emergency Economic Powers Act (IEEPA) were unlawful, companies have a rare opportunity to recover billions of dollars. With over $165 billion in tariff revenue collected and an estimated $10 billion+ in accruing interest, the time to act is now.

However, getting your money back isn't as simple as submitting a standard claim.

Why choose KPMG?

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One firm, one coordinated filing

One firm, one coordinated filing

We consolidate the submission process, eliminating the complexity and inconsistency of managing multiple brokers and piecemeal filings.

Technology-enabled, scalable execution

Technology-enabled, scalable execution

Leveraging our proprietary trade analytics and Tariff Modeler on KPMG Digital Gateway, we generate custom IEEPA recovery ACE data reports based on KPMG customization protocols and analyze the data at scale. We build the complete "entry universe" segment according to CAPE's strict rules, and sequence our CAPE declaration submission strategies while tracking future tariff payments for potential recovery. 

Audit-ready financial tracking

Audit-ready financial tracking

Our IEEPA tracking dashboard in Digital Gateway provides end-to-end tracking of every claim, tying the consolidated cash refund directly back to the original entry for your finance and accounting teams.

Advisory beyond the filing

Advisory beyond the filing

Unlike brokers, KPMG provides holistic support on accounting considerations (e.g., ASC 740), audit-readiness, and governance around claims and controls, enabling you to evaluate when and how benefits should be recognized. For entries ineligible for Phase 1 or that may require protests, KPMG maintains a consolidated list of remaining entries to be addressed via subsequent CAPE phases and protests.

Credibility and confidence

Credibility and confidence

As a global accounting and advisory firm, we bring a defensible methodology and institutional credibility that matters when refunds are large and subject to internal and external scrutiny.

Flexible commercial models aligned to value

Flexible commercial models aligned to value

We offer flexible pricing arrangements, including success-based fee models, fixed-fee engagements for defined scopes of work, and per-entry pricing where appropriate. The specific approach will depend on your importer profile, the level of effort required, and any applicable independence considerations.

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The KPMG approach: A proven data-driven process

Don't leave money on the table or introduce unnecessary risk. KPMG offers a consolidated, technology-enabled data-driven approach designed to recover cash efficiently while minimizing rework and error.

Request a demo of the KPMG Tariff Modeler.

The KPMG approach to tariff modeling leverages the latest technologies while considering the data needed to navigate today’s global trade disruption.

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The KPMG approach to tariff modeling leverages the latest technologies while considering the data needed to navigate today’s global trade disruption.

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