How Companies Are Accounting for Expected IEEPA Refunds

Controllers and CFOs are asking when an expected IEEPA refund can be recorded. This is a summary of published guidance from two large accounting firms. It is general information, not accounting advice. Talk to your CPA or auditor.

Deloitte's view

• Preferred approach: a loss-recovery model by analogy, recognizing a refund asset for previously recognized tariff costs once recovery is probable.
• Alternative: a gain-contingency model, which waits until the gain is realized or realizable.
• Interest is recognized only when all contingencies are resolved.
• How probable recovery is may differ by CAPE phase and entry status.
• The guidance also covers tariffs capitalized in inventory, cash-flow classification of refunds, and arrangements that monetize refund rights.

KPMG's view

KPMG also describes a loss-recovery model, limited to losses incurred where recovery is probable, and notes a rebuttable presumption that a claim subject to dispute is not probable.

What this means for companies

Neither firm treats an expected IEEPA refund as a simple receivable. An entry already accepted in CAPE is in a different position from a finally liquidated entry that depends on litigation. Share your entry-by-entry status with your auditor. See how to pull ACE refund reports.

General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.