Tariffs Remain a Strategic Business and Tax Concern

As tariffs remain a dominant theme of tax and trade policy negotiations,  they are expected to present significant business challenges through 2027. Ongoing tariff actions and retaliatory trade measures are prompting businesses to strengthen supply chain resilience, tighten cash flow controls, improve documentation, and expand contingency planning. Beyond operational concerns, organizations must continue to evaluate the impacts of  tariff exposure, compliance obligations, and potential refund opportunities on their broader tax and accounting positions.

The administration continues to impose tariffs under other trade and national security provisions. These measures remain broad in scope, covering products from multiple countries and, in some cases, layering additional tariffs on top of existing duties. As a result, many businesses continue to face complex compliance, tax, accounting, and planning challenges.

CBIZ helps businesses identify where tariffs are affecting operations and uncover planning opportunities to optimize their position. A customized review of tax, sourcing, and pricing strategies can help mitigate exposure, improve preparedness, and support long-term resilience. Typically, such an exercise should align procurement, finance, tax, operations, customs, legal, and sales teams in a business. These teams should coordinate to identify risks and model exposure and determine where pricing or contract changes may be required. Integrated planning, supply-chain scenario modeling, automation, foreign trade zones, duty drawbacks, and coordinated customs and tax planning can improve visibility and reduce unnecessary duty cost.

In addition to managing ongoing tariff exposure, businesses should evaluate whether they may be eligible for refunds resulting from recent legal challenges to certain tariff programs.

Tariff Refunds

Recent legal challenges to the Trump administration’s use of authority under the International Emergency Economic Powers Act (IEEPA) resulted in the invalidation of certain tariffs on imported goods. As a result, a large-scale refund process is now underway, with approximately $166 billion plus interest expected to be refunded to affected importers.

For importers of record and licensed customs brokers, U.S. Customs and Border Protection (CBP) has established an administrative process for claiming IEEPA-related tariff refunds:

• Phase 1 (launched April 20, 2026): Covers unliquidated entries and entries no more than 80 days past liquidation.
• Phase 2 (launched June 29, 2026): Runs concurrently with Phase 1 and addresses certain entities flagged for reconciliation.
• Phase 3: Currently under development and expected to address older liquidated entries. Timing remains uncertain as of publication.

Indirect Tariff Refunds

Businesses that indirectly absorbed tariff costs currently have no formal mechanism for filing refund claims. However, organizations can begin assessing where tariff costs were passed through the supply chain, evaluating contractual rights, and identifying potential recovery opportunities.

Insight: CBIZ works with businesses across the supply chain to identify and support potential recovery opportunities. We coordinate with customs brokers, finance teams, legal counsel, and other stakeholders to:

• Identify tariff pass-through exposure across suppliers, contracts, and pricing arrangements.
• Review and validate documentation supporting legal or contractual claims.
• Support supplier engagement and negotiation efforts.
• Assess the tax and accounting implications of potential recoveries and refunds.

Learn more: Indirect Tariff Payers May Be Overlooking a Meaningful Recovery Opportunity

Tax Treatment of Tariff Refunds

As refund claims move forward, taxpayers are increasingly asking about the federal income tax treatment of any amounts received. The answer, as is often the case in tax matters, depends on the specific facts and circumstances.

When tariffs were previously deducted for federal income tax purposes, any related refund may constitute a recovery of an item that generated a prior-year tax benefit. Under the tax benefit rule, a recovery is generally taxable only to the extent the original deduction produced a tax benefit, such as reducing taxable income or increasing a loss carryforward.

Read The U.S. Federal Income Tax Treatment of Tariff Refunds to better understand:

• Refunds of Tariffs Paid on Deducted Items
• Tariffs Related to Purchases of Inventory
• Refunds of Tariffs on Fixed Asset Purchases
• Refund of Tariffs on Personal or Non-Deductible Purchases

Explore CBIZ Integrated Solutions to learn how tariffs are reshaping middle-market businesses and which actions to take.