IEEPA Tariff Refund Claims

Background

Federal courts have held that broad IEEPA import tariffs were unlawful, but recovery outcomes remain uneven across importers.

CBP has processed many refunds through the CAPE process, yet it has maintained that it lacks administrative authority to refund entries that are finally liquidated and outside protest windows. For many affected companies, action in the Court of International Trade (CIT) may be the only remaining route to recovery.

Our role

VL Capital Management is supporting affected importers and customs brokers through a Tariff Claim Asset Program with two non-recourse tracks:

Track A: Outright cash purchase

• We purchase unpaid IEEPA tariff refund claims through a legal assignment structure.
• Claimants receive immediate liquidity.
• We assume the collection and litigation risk.

Track B: 100% litigation funding

• We fund legal fees, court costs, and administrative expenses required to pursue CIT recovery.
• The structure is non-recourse: if there is no recovery, the claimant owes nothing.
• Compensation is based on a pre-agreed share of recovered proceeds, where applicable.

Strategic focus

We are prioritizing claims most exposed to administrative deadlock, including:

• Entries liquidated more than 90 days ago and outside standard protest timelines.
• Entries with no active protest or CAPE validation path.
• Entries excluded due to filing, timing, or Chapter 99 designation issues.

Current status

This is an active case area we are currently working on.

Importers and brokers are engaging us to:

• Protect cash flow by monetizing delayed claims.
• Reduce legal and process burden through a funded pathway.
• Work with a team familiar with ACE and CAPE data workflows, CIT procedure, and claim transfer mechanics.