Supreme Court overturns IEEPA tariffs

We believe it is acceptable to treat the Supreme Court’s decision as a nonrecognized (Type 2) subsequent event in financial statements that have not yet been issued as of February 20, 2026.

If the Supreme Court’s ruling is expected to have a material effect on the financial statements when recognized, or not disclosing it would otherwise result in the omission of material information to financial statement users, companies should disclose the nature of the decision and its expected implications. Such disclosures may address, for example, the potential effect on existing  and future tariff exposure, supply chain arrangements, liquidity or ongoing or anticipated legal proceedings. Any estimate of financial effects is based on information known as of the date the financial statements are issued (or available to be issued), and companies should avoid speculative or overly forward‑looking statements.

As with all subsequent events analyses, conclusions should be grounded in company‑specific facts and circumstances. Companies should also consider whether related disclosures are required under other US GAAP topics, such as ASC 275 on risks and uncertainties, ASC 205-40 on going concern or ASC 450 on contingencies.

Given the ongoing uncertainty regarding potential refunds of previously imposed tariffs, companies should continue to monitor developments in this area.