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National Law Review
National Law Review
6/18/2026
What Every Multinational Should Know About … The Government’s IEEPA Federal Circuit Appeal

What Every Multinational Should Know About … The Government’s IEEPA Federal Circuit Appeal

Short summary

The U.S. Government is appealing a Court of International Trade ruling requiring refunds of unlawfully collected IEEPA tariffs, arguing it can retain $30+ billion for "finally liquidated" entries. Multinational importers who haven't filed protective actions under §1581(i) face significant delays and potential loss of refunds. Filing protective actions is now critical for companies with substantial unliquidated, reconciliation, or antidumping-affected entries.

  • Government appeals ruling, seeks to keep $30B+ in tariff payments for finally liquidated entries
  • Importers without filed protective actions face delays and potential loss of refunds
  • Filing §1581(i) protective actions is critical for refund recovery

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