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• Comment: Started to do some cleanup for your draft but this is just an advertisement, for which we are not interested. Bobby Cohn 🍁 (talk) 15:29, 10 April 2026 (UTC)

The Tariff Refund Project is a legal initiative operated by Grayhawk Law, a Los Angeles–based constitutional litigation firm. It was established in 2026 following a decision by the Supreme Court of the United States that invalidated certain tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The initiative provides legal services related to the recovery of tariff payments through the U.S. customs protest process.

IEEPA Tariffs
Beginning in 2025, the executive branch imposed a series of tariffs under the International Emergency Economic Powers Act (IEEPA), affecting a broad range of imported goods and industries. Businesses were required to pay these tariffs at the time of import, resulting in significant additional costs across sectors of the U.S. economy.^[1]

Following a February 20, 2026 decision by the United States Supreme Court invalidating the tariffs, businesses began seeking ways to recover payments that had already been made. However, the process for obtaining refunds has been described as complex and uncertain, requiring importers to navigate procedural requirements and legal constraints.^[2] Businesses importing goods subject to these tariffs were required to pay them at the border as a condition of entry, resulting in substantial additional costs absorbed by importers, retailers, and consumers. According to a declaration from a U.S. Customs and Border Protection official, over 15 million entries were liquidated with IEEPA duties on or before December 4, 2025, involving more than 330,000 importers.^[3]

On February 20, 2026, the United States Supreme Court issued a landmark decision holding that the IEEPA tariffs were unlawful, finding that the executive branch had exceeded its statutory authority under the statute.^[4](via Yahoo News)The ruling invalidated the tariffs but did not automatically trigger refunds for the businesses that had already paid them. This gap — between the Court's ruling and the practical ability of businesses to recover their payments — contributed to the creation of the Tariff Refund Project.

Overview
Under U.S. Customs law, importers may contest tariff assessments by filing a formal protest with U.S. Customs and Border Protection (CBP). Following the Supreme Court ruling, businesses that paid IEEPA tariffs became eligible to file such protests to seek refunds. However, this right is subject to a strict 180-day deadline measured from the date of each individual tariff payment.

Because tariffs were collected on a rolling basis as goods entered the country, the 180-day window runs separately for each customs entry. Businesses that miss the deadline for a given shipment permanently forfeit the right to a refund on that entry. The legal and procedural uncertainty surrounding tariff refunds has led to confusion among affected businesses, particularly small and mid-sized importers attempting to determine whether and how to file claims within applicable deadlines.^[5]

Legal complexity of the refund process

The refund process has proved more legally complex than many importers anticipated. In March 2026, Court of International Trade Judge Richard Eaton ordered CBP to begin refunding IEEPA tariffs for unliquidated and non-finally liquidated entries, but stayed that order days later pending further proceedings.^[6] A central legal dispute concerns the meaning of "finally liquidated" — specifically, whether entries become finally liquidated at the end of CBP's 90-day voluntary reliquidation window, or at the end of the separate 180-day protest window available to importers. Trade attorneys have noted that the distinction matters greatly for determining how many entries are covered by court refund orders.^[7]

Why refunds are not automatic

The Supreme Court's ruling does not trigger automatic reimbursement. The federal government does not proactively identify affected importers or remit payments. Each business must independently identify the customs entries for which IEEPA tariffs were paid, calculate the amounts owed, file a formal protest with CBP within the applicable 180-day window, and pursue the protest through the administrative process — and through litigation if necessary. Of the more than 330,000 importers that paid IEEPA tariffs, only approximately 6,000 hold the Automated Commercial Environment (ACE) accounts that CBP has indicated are necessary to process refund payments electronically.^[8] This limitation has been cited as a barrier for some importers navigating the refund process.

Class action considerations

In early 2026, an importer filed suit in Freestyle World v. United States seeking class certification on behalf of all importers with IEEPA tariff liability under $1 million who had not individually filed suit seeking refunds.^[9] Trade attorneys have noted that a class action approach may face legal obstacles, particularly regarding the role of individual protest filings. Because each importer would present different facts — including when and whether a protest was filed — a class action may not be the appropriate vehicle for all claimants, making individual protest filings especially important for businesses seeking to protect their refund rights.^[10]

The Tariff Refund Project is an initiative of Grayhawk Law, a Los Angeles–based litigation firm founded by Matthew A. Seligman, a constitutional law attorney and legal scholar, who has taught at Harvard Law School and served as a fellow at Stanford Law School’s Constitutional Law Center. Seligman has been quoted in national media coverage of the IEEPA tariff litigation and its aftermath, including reporting on the legal challenges surrounding the tariffs and the process for obtaining refunds.

He has also appeared in broadcast coverage discussing the implications of the ruling and the broader legal landscape surrounding tariff enforcement and recovery efforts.^[11] Seligman has served as counsel representing importers seeking refunds of IEEPA tariff payments through the customs protest and litigation process.^[12]

===Services=== Through TariffRefundProject.com, Grayhawk Law provides legal services to importers seeking refunds of IEEPA tariff payments, including the preparation and filing of customs protests with U.S. Customs and Border Protection, and representation in related administrative and judicial proceedings.

The tariffs affected businesses across multiple industries, including retail, consumer goods, food and beverage, apparel, and manufacturing sectors.

Matthew A. Seligman has been quoted in media coverage on constitutional law and executive power. In 2026, he was widely quoted in connection with the legal dispute between Anthropic and the U.S. Department of Defense, in which the Pentagon designated the AI company a "supply chain risk" after it refused to remove safety guardrails from its AI system.^[13] Seligman argued that the case raised significant First Amendment questions, noting that AI models function as "speech machines" whose outputs are information rather than physical products, and that the law would need to develop new frameworks to analyze them.^[14] He also warned of the broader implications for companies and investors if the government were permitted to designate contractors as security risks as a means of compelling compliance: "If you give the government a license to kill companies, then companies are always going to be under threat of execution."^[15] His commentary was later cited in a follow-up article reporting that a federal judge signaled the Pentagon's actions appeared to constitute unlawful retaliation against Anthropic.^[16] Seligman has also commented on the broader context of executive power under the current administration: "This is by far the most aggressive administration in certainly recent and probably all of American history with respect to executive power."^[17]

The Tariff Refund Project and its principals have been referenced in national and trade publications, including:

• The New York Times
• POLITICO
• Law.com
• Bloomberg Businessweek
• Trade Law Daily
• International Trade Today
• Quartz

International Emergency Economic Powers Act United States Customs and Border Protection Customs protest (U.S. trade law) Freestyle World v. United States Grayhawk Law

• TariffRefundProject.com — Official project website
• Grayhawk Law — Firm website