Every executive we work with asks the same thing: “Can you give me the one-pager?” They don’t want the full legal analysis, the entry-level spreadsheet, or the historical timeline. They want a single document that tells them what’s happening, what to do, and when to do it.
This is that document — expanded here with context and explanation, but designed to be condensed into a single printed page for internal use. At the end of this article, you’ll find the actual one-page template you can fill in with your company’s specific numbers.
The Situation in 60 Seconds
The Supreme Court ruled 6-3 on February 20, 2026, that IEEPA tariffs collected between February 4, 2025, and February 24, 2026, are unconstitutional. The CIT ordered CBP to process refunds on March 4, 2026. Every dollar your company paid in IEEPA tariffs during that period is legally refundable.
The estimated total market: $166 billion across all U.S. importers.
Your company’s estimated exposure: $[YOUR AMOUNT].
This isn’t speculative. This isn’t a pending case. The ruling is final, the refund mechanism is in motion, and the only question is how quickly and efficiently you recover what you’re owed.
The Three Things That Matter Right Now
Out of everything written about IEEPA recovery — and there’s a lot — only three things require immediate executive attention:
1. You Have Deadlines
The 180-day protest window is running on entries that have already been liquidated. This window cannot be extended, and missing it pushes entries to the more expensive CIT litigation path. Some of your entries may have deadlines approaching within weeks.
Action required: Identify approaching deadlines and file protective protests immediately.
2. Your Queue Position Matters
CBP will process refund claims through the CAPE system on a first-come, first-served basis. With 330,000+ importers and limited processing capacity, the difference between filing early and filing late could be 12-24 months of additional wait. Your filing position depends on having validated data ready before CAPE launches.
Action required: Begin data preparation now. Don’t wait for CAPE to go live.
3. You Have Multiple Recovery Options
Not all of your entries will follow the same path. The four recovery paths — PSC, protest, CIT litigation, and immediate capital — each apply to different entry categories based on liquidation status and your financial priorities.
Action required: Get an Impact Assessment to determine which path applies to each group of entries.
The 30-Day Action Plan
Here’s your roadmap, broken into weekly objectives with specific deliverables and responsible parties.
Week 1: Data and Assessment
| Action | Owner | Deliverable | Deadline |
|---|---|---|---|
| Request ES-003 report and entry data from broker(s) | Logistics / Trade Compliance | ACE data in CSV/Excel | Day 3 |
| Submit Impact Assessment request | CFO / Controller | Confirmation email | Day 1 |
| Identify all customs brokers used during IEEPA period | Logistics / AP | Complete broker list | Day 2 |
| Pull internal customs duty payment records | Controller / AP | AP summary by month | Day 5 |
| Compile data preparation package | Finance team | Data folder organized | Day 7 |
Week 2: Analysis and Urgency
| Action | Owner | Deliverable | Deadline |
|---|---|---|---|
| Review broker data for approaching protest deadlines | Assessment team / Finance | Deadline calendar | Day 10 |
| File protective protests on at-risk entries | Customs broker | Filed protest confirmations | Day 10 (urgent) |
| Complete discovery call with assessment team | CFO / Finance lead | Call completed | Day 8-10 |
| Begin entry classification (unliquidated vs. liquidated) | Assessment team | Status spreadsheet | Day 14 |
Week 3: Assessment and Strategy
| Action | Owner | Deliverable | Deadline |
|---|---|---|---|
| Receive and review Impact Assessment | CFO / Decision maker | Assessment report reviewed | Day 17 |
| Model recovery scenarios (government vs. immediate capital) | CFO / Controller | Financial comparison | Day 19 |
| Evaluate advisory firm options (if proceeding with professional management) | CFO | Firm evaluation matrix | Day 21 |
| Determine internal vs. professional management approach | CFO | Decision documented | Day 21 |
Week 4: Decision and Execution
| Action | Owner | Deliverable | Deadline |
|---|---|---|---|
| Present recovery recommendation to board/executives | CFO | Board presentation | Day 22-25 |
| Obtain authorization to proceed | Board / Executive team | Approved recommendation | Day 25-28 |
| Execute advisory engagement (if applicable) | CFO | Signed agreement | Day 26-28 |
| Begin PSC filings for unliquidated entries | Customs broker | Filed PSC confirmations | Day 28-30 |
| Initiate CAPE preparation | Advisory team / Broker | Data validation underway | Day 28-30 |
Key Decision Points
Across the 30-day plan, you’ll face three major decisions. Each has a clear framework.
Decision 1: Professional Advisory or DIY?
Choose professional if: Your portfolio exceeds 30 entries, involves multiple brokers, has entries approaching protest deadlines, or your team lacks trade compliance expertise. The DIY vs. professional comparison provides a detailed scoring framework.
Choose DIY if: Your portfolio is under 20 entries, all with a single broker, and your broker is experienced with IEEPA recovery procedures.
Decision 2: Government Filing, Immediate Capital, or Split?
Choose government filing if: You have no urgent capital needs, your cost of capital is below 8%, and you can tolerate a 12-36 month timeline.
Choose immediate capital if: You need cash within 60 days, your cost of capital exceeds 12%, or entries face documentation or deadline challenges.
Choose split if: You have entries in multiple categories — which most mid-market importers do. The government filing vs. claim sale guide walks through the split analysis.
Decision 3: Which Firm?
If you decide to use professional advisory, evaluate firms on: fee structure, scope of services, IEEPA experience, data security practices, and contract flexibility. The firm evaluation guide provides a comparison matrix and red flags to watch for.
The Numbers You Need
Fill these in from your Impact Assessment to complete your one-page plan:
Exposure Summary
| Metric | Your Number |
|---|---|
| Total IEEPA duties paid | $_________ |
| Number of qualifying entries | _________ |
| Unliquidated entries (PSC eligible) | $_________ / _____ entries |
| Liquidated within protest window | $_________ / _____ entries |
| Liquidated past protest window | $_________ / _____ entries |
| Earliest approaching protest deadline | _________ (date) |
Recovery Projections
| Path | Estimated Recovery | Timeline | Cost |
|---|---|---|---|
| Government filing (net of fees) | $_________ | _____ months | $_________ |
| Immediate capital (net) | $_________ | _____ weeks | $_________ |
| Split strategy (net combined) | $_________ | _____ months | $_________ |
Cost of Inaction
| Risk | Estimated Impact |
|---|---|
| Entries past protest deadline (lost to simple recovery) | $_________ |
| Time value erosion at ___% WACC per quarter | $_________ |
| Additional CIT legal fees for missed deadlines | $_________ |
| Total quarterly cost of inaction | $_________ |
The One-Page Template
Here is the actual one-page document. Copy this framework, fill in your numbers, and distribute to your decision makers.
IEEPA TARIFF REFUND RECOVERY ��� EXECUTIVE ACTION PLAN
Company: [Name] | Date: [Date] | Prepared by: [Name/Title]
THE OPPORTUNITY
The Supreme Court ruled all IEEPA tariffs unconstitutional (Feb 20, 2026). Our company paid $[AMOUNT] in IEEPA duties across [N] entries between Feb 2025 and Feb 2026. This amount is fully refundable plus statutory interest.
OUR EXPOSURE
- Unliquidated entries (fastest recovery): $[X] across [N] entries
- Liquidated, within protest window: $[X] across [N] entries
- Liquidated, past protest window: $[X] across [N] entries
- URGENT: [N] entries have protest deadlines within 60 days
RECOMMENDED STRATEGY
[Describe your recommended approach — e.g., “File PSCs on unliquidated entries, file protests on recently liquidated entries, sell [N] at-risk entries for immediate capital”]
- Projected net recovery: $[X]
- Estimated timeline: [X] months to first payment, [Y] months to full resolution
- Total cost (advisory + filing + legal): $[X]
- Net ROI: [X]x
COST OF INACTION
- $[X]/quarter in time value erosion
- $[X] at risk from approaching protest deadlines
- Queue position deterioration adds [X] months to processing
AUTHORIZATION REQUESTED
- Engage [firm] for recovery management at [fee terms]
- Authorize data sharing under mutual NDA
- Authorize immediate protective protest filings ($[X] in broker fees)
- [If applicable] Authorize claim sale of [N] entries for ~$[X] immediate capital
Decision requested by: [Date] — to protect entries approaching [deadline date]
Tracking Progress: Monthly Status Indicators
Once you’ve started execution, track these metrics monthly to ensure your recovery stays on schedule.
Green Indicators (On Track)
- All data received from broker(s) and validated
- Protective protests filed on all at-risk entries
- CAPE declarations submitted and accepted
- Assessment completed with clear recovery path assignments
- Decision maker briefed and authorization obtained
- Advisory engagement (if applicable) active and reporting
Yellow Indicators (Attention Needed)
- Broker data incomplete — some entries missing
- One or more CAPE declarations rejected (awaiting correction)
- Approaching protest deadlines within 60 days with no protective filing
- Internal decision pending beyond two weeks of assessment delivery
- Advisory firm communications irregular or unclear
Red Indicators (Immediate Action Required)
- Protest deadline within 30 days with no filing
- CAPE declarations rejected with no resubmission plan
- Broker unresponsive for more than 5 business days
- No assessment initiated and total exposure unknown
- Evidence of duplicate filings or conflicting actions
Review these indicators at your regular financial reporting cadence. The cost of waiting compounds on a measurable schedule — catching a yellow indicator before it turns red can save thousands of dollars and months of delay.
Reporting to Stakeholders
Once recovery is underway, your board and leadership team will want updates. Keep reporting simple:
| Metric | Starting Value | Current | Target |
|---|---|---|---|
| Total IEEPA exposure | $[X] | $[X] | N/A (fixed) |
| Entries filed (CAPE/PSC/Protest) | 0 | [N] | All qualifying entries |
| Entries processed (refund issued) | 0 | [N] | All filed entries |
| Refund received to date | $0 | $[X] | $[total exposure] |
| Immediate capital received | $0 | $[X] | $[sold entries value] |
| Approaching deadlines | [N] | [N] | 0 |
One slide with this table at each board meeting keeps stakeholders informed without consuming agenda time.
Common Modifications by Company Size
For Companies Under $5M Annual Imports
Your total IEEPA exposure is likely under $100,000. The action plan simplifies:
- Skip the formal board presentation — a brief email to the owner/CEO is sufficient
- The DIY approach may be appropriate if your entries are straightforward
- Focus on PSC filing through your broker — this is likely your primary recovery path
- Consider whether the effort is worth it for exposures under $10,000 (usually yes for PSC-eligible entries, maybe not for protest-path entries with complications)
For Companies $5M-$50M Annual Imports
This is the mid-market sweet spot where the full action plan applies. Your exposure likely justifies professional advisory, your portfolio probably includes mixed-status entries requiring multiple recovery paths, and the financial stakes are material to your business.
For Companies Over $50M Annual Imports
Your exposure may be in the millions. The action plan scales up:
- Add a dedicated internal project lead for IEEPA recovery coordination
- Engage both advisory and legal counsel from the start (CIT litigation is likely for some entries)
- Consider a phased claim sale strategy to generate immediate capital while pursuing government filing on the bulk
- Implement monthly steering committee reviews (not just board updates)
- Coordinate across business units if multiple divisions import independently
How to Use This Plan
For the CFO
This plan is your internal communication tool. Fill it in with your assessment data, present it to your board using the board presentation framework, and use it as the basis for tracking progress after authorization.
For the Controller
Use the numbers section to coordinate with your auditor on financial statement treatment. The recovery projections inform your receivable accruals and cash flow forecasting.
For the Logistics Lead
Use the action plan to coordinate with customs brokers. The broker email templates provide ready-to-send requests for the data items on the Week 1 task list.
For Legal Counsel
Review the recovery strategy for legal sufficiency, particularly around claim assignment terms (if immediate capital is part of the plan) and NDA requirements for data sharing with the advisory firm.
When the Plan Goes Off Track
No plan survives contact with reality entirely intact. Here’s how to handle common deviations.
Your Broker Can’t Provide Data in Time
If your broker is unresponsive or slow, don’t wait. Submit your Impact Assessment request with whatever internal data you have — AP records, broker invoices, estimates. The assessment process is iterative and designed to work with imperfect information. Simultaneously, escalate with your broker or explore alternative data sources.
Your Board Defers the Decision
If your board tables the discussion or requests more information, don’t let the recovery process stall. Ask for authorization to take two immediate, low-risk actions: (1) file protective protests on entries approaching deadline expiration and (2) continue data gathering and preparation. These actions preserve options without committing to a full recovery strategy.
You Discover Your Exposure Is Smaller Than Expected
Even a $30,000 recovery is worth pursuing if the filing path is straightforward. For PSC-eligible entries, the broker filing cost is typically $50-$200 per entry — a small fraction of the recovery. Only portfolios under approximately $10,000 with complex filing requirements may genuinely not justify the effort.
You Discover Your Exposure Is Larger Than Expected
This happens more often than you’d think. Importers who estimate $200,000 in exposure sometimes discover $800,000 or more when the data comes back. If your exposure is significantly larger than expected, consider upgrading from DIY to professional advisory and evaluating the split strategy for faster partial recovery.
A Deadline Was Missed
If you discover that a protest deadline has already passed on some entries, don’t panic. Those entries still have recovery options — either through CIT litigation or through claim sale. The recovery may be more expensive or yield a lower percentage, but the money isn’t lost. Adjust your plan and move forward.
Getting Your Numbers
The one-page plan is only as good as the data behind it. If you don’t yet have the numbers to fill it in, that’s your immediate next step.
Get your free Impact Assessment →
The Impact Assessment produces every number on this template — total exposure, entry statuses, recovery projections, deadline calendar, and recommended strategy. It’s free, confidential, and typically completed within 5-14 business days. Request yours today and have a complete, board-ready action plan within two weeks. The cost of waiting grows every day — start now.
