What do organizations need to do to be able to file a CAPE Declaration?

Importers of records should ensure ACE system access and complete the ACH refund program information. CBP has provided the following helpful links: Updated ACE Entry Summary Error Dictionary CSMS # 68340863 - UPDATE - Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds CBP Modernizes Electronic Refund Enrollment Process

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Tariff Impact Advisory

Tariffs and broader trade policy can affect a business’s accounting, audit, and financial reporting functions and influence key operational decisions. Cherry Bekaert is positioned to advise clients on the impacts of trade policy on those functions, providing practical advice and helping to determine appropriate strategies.

Tariff Impacts Across Tax, Accounting and Advisory

Tariffs continue to be a top concern for businesses navigating an increasingly complex global trade environment. Many organizations are actively seeking clarity around current regulations, future policy changes, and the financial and operational impacts on their business.

From financial statements and income tax to transfer pricing and supply chain decisions, understanding how these changes flow through your business is critical.

Integrated Tariff Insights To Support Informed Decision Making

To support these needs, Cherry Bekaert has mobilized practical resources and timely insights designed to help organizations identify risks, uncover opportunities and take informed next steps.

Our teams bring a cross-functional approach to help businesses assess how trade-related developments affect their financial reporting, federal and state income tax, quarterly and annual provisions, and transfer pricing. We go further, providing practical approaches to addressing these impacts. This coordinated approach aids organizations in maintaining tax and financial reporting compliance and instituting comprehensive, effective practices across operations.

Discuss Next Steps for Tariff Developments

Connect with our cross-functional team of advisors to learn about how organizations are responding after tariff changes and what actions may be needed across accounting, audit, tax and financial reporting.

Key Tariff Developments Timeline

Cherry Bekaert professionals are monitoring tariff activity and updating this page as new developments occur.

Q1 2026

February 20, 2026

Supreme Court rules IEEPA tariffs unconstitutional; Trump administration announces Section 122 tariffs

February 24, 2026

Section 122 tariffs go into effect

March 4, 2026

U.S. Court of International Trade orders U.S. Customs and Border Protection (CBP) to begin refunding IEEPA duties

March 6, 2026

U.S. Court of International Trade pauses refund order as CBP requests time to prepare large-scale refund process

March 11, 2026

U.S. initiates Section 301 investigations into global manufacturing capacity

March 12, 2026

CBP provides update on refund process and Automated Commercial Environment (ACE) system; additional Section 301 investigations announced

March 27, 2026

U.S. Court of International Trade expands refund scope to include certain finalized entries

March 31, 2026

CBP files status update outlining progress on the Consolidated Automated Processing Environment (CAPE) refund system

Previous Developments

Q1 2025

January 20, 2025

President Trump signs the America First Trade Policy Executive Order

February 1, 2025

International Emergency Economic Powers Act (IEEPA) fentanyl-related tariffs are announced

February 10, 2025

First expansion of Section 232 tariffs

Q2 2025

April 2, 2025

IEEPA reciprocal tariffs announced (Liberation Day) and later paused

May 28–29, 2025

Initial rulings issued in Trump v. V.O.S. Selections and Learning Resources, Inc. v. Trump

Q3 2025

August 7, 2025

IEEPA reciprocal tariffs go into effect

How We Help Across Service Lines

Cherry Bekaert brings together professionals across our accounting — including forensic accounting — audit, tax and advisory teams, to help organizations evaluate the financial, tax, and operational implications of tariff developments and related refunds.

As tariffs appear to remain a significant component of U.S. trade policy for the coming years, Cherry Bekaert’s team of business optimization and technology advisors can help institute leading practices from a systems perspective.

Accounting and CFO Advisory Services

Our teams provide guidance on implementing financial reporting, managing operational challenges, addressing tax uncertainties and managing cash flow. Cherry Bekaert’s CFO Advisory team is positioned to help organizations navigate the financial and operational repercussions of the current and post-tariff world.
Audit and Attestation Services

We help organizations assess the accounting and financial statement impacts of tariff payments and refunds, including classification, recognition and related documentation. Our Assurance team has experience across multiple industries, delivering audits and guiding clients on various financial, internal control and operational questions.
Corporate Tax and ASC 740 Services

Refunds of duties present a range of direct and indirect considerations for both U.S. federal income tax compliance and financial reporting in accordance with ASC 740. As the tax and accounting implications can vary significantly by organization, it is essential for each entity to conduct a thorough analysis of the specific effects relevant to their circumstances. Our Corporate Tax Services team has the experience to guide organizations through the tax and provision impact of the tariffs and tariff-related refunds.
Forensic and Dispute Advisory Services

Our Forensic and Dispute Advisory teams’ involvement begins once organizations are proceeding down a formal program or process to apply for a refund, file a protest or when legal counsel is otherwise engaged. They are strategically positioned to support legal counsel and businesses with the accounting, data analysis, and calculation work needed to substantiate potential refund claims or in the event of a dispute.
Transfer Pricing and Cross-border Implications

With U.S. international tax being another layer upon domestic filings, it is important to understand how changes to taxable income may impact the international tax provisions applicable to a taxpayer, such as FDDEI calculations and FTC limitations. If an organization’s supply chain involves related parties, transfer pricing considerations need to be considered for who is bearing the current cost or entitled to refunds. Our International Tax team is poised to assist clients as these complicated issues arise.
Tax and Tariff Policy

Our Tax Policy and Legislative Changes team monitors tariff-related developments, court rulings and regulatory changes to provide timely, digestible insights on what is changing and how it may affect organizations.
State and Local Tax Services

Whether it is IEEPA refunds or other tariffs, the implications for state and local taxes are primarily prospective, with operational and compliance considerations that importers should evaluate going forward. Our State & Local Tax (SALT) teams assist taxpayers with considerations of what refunds would mean for sales and use tax, income tax, gross receipts taxes, and inventory taxes.

Tariff Refund Frequently Asked Questions (FAQs): What You Need To Know About Recent Developments

Importers of record or their designees are entitled to refunds.

U.S Customs and Border Protection (CBP) has created the Consolidated Administration and Processing of Entries (CAPE) functionality within the Automated Commercial Environment (ACE). Importers of record or customs brokers with ACE access may file a CAPE Declaration (refund request).

CAPE is an add-on functionality in four components within ACE, purposely designed to manage IEPPA tariff refunds. The four components are: (i) Claim Portal, (ii) Mass Processing, (iii) Liquidation/Reliquidation and (iv) Refund. The CAPE functionality is meant to validate claims, recalculate the correct tariffs without IEEPA tariffs, calculate the interest owed and issue the refund.

Importers of records should ensure ACE system access and complete the ACH refund program information. CBP has provided the following helpful links:

CBP has stated the intention is that CAPE functionality will process to some extent all IEEPA tariff refund claims. To meet the U.S. Court of International Trade deadline of April 20, 2026, CAPE functionality is being rolled out in phases. Phase I CAPE functionality is intended to process certain unliquidated entries and certain liquidated entries that have been liquidated within the last 80 days.

CAPE functionality within the ACE went live on April 20, 2026, at 8:00 A.M. ET.

CBP expects to process a CAPE Declaration and issue a refund 60 – 90 days after it has been accepted.

Businesses that paid tariff costs indirectly should review legal agreements to understand how refunds or price adjustments are addressed (if at all), and to the extent possible, understand what amount of IEEPA tariffs were passed along to them. Businesses may need to consult legal counsel for advice on what civil remedies exist for reimbursement. If you find your business having borne such costs while not being an importer of record, a conversation with Cherry Bekaert’s Forensic & Dispute Advisory Services team may be helpful.

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