What We Do

Thompson LLP advises businesses navigating the legal and commercial implications of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). These tariffs, implemented through presidential emergency powers beginning in 2025, affected a wide range of industries and supply chains, often creating significant and unexpected financial exposure for importers of record, U.S. businesses, and foreign suppliers.

Our attorneys assist clients in assessing how IEEPA tariffs affect their operations, contractual relationships, and potential recovery rights. We provide practical guidance to businesses seeking to understand their legal options, evaluate potential claims, and navigate the complex regulatory and litigation landscape surrounding these measures.

IEEPA tariffs have created a range of legal and commercial issues, including refund eligibility, contractual cost allocation, and disputes among supply chain participants. Our team works closely with clients to evaluate the facts of each situation and develop strategies aligned with their business objectives.

Understanding IEEPA Tariffs

The International Emergency Economic Powers Act authorizes the President to regulate international commerce during a declared national emergency. Beginning in 2025, the administration invoked IEEPA authority to impose substantial tariffs on imports from numerous countries.

These measures were implemented quickly and affected businesses across a wide spectrum of industries. Many companies faced significant duties on previously routine imports, often without the advance planning or regulatory processes typically associated with other tariff regimes.

Recent developments, including the U.S. Supreme Court’s decision in Learning Resources, Inc. v. Trump, which held that IEEPA does not authorize the President to impose tariffs, have created significant questions regarding the validity and administration of these measures. As a result, businesses that paid or absorbed these duties may have legal avenues to seek refunds or other recovery, depending on their role in the supply chain and the specific facts involved.

Our Approach

Thompson LLP combines experience in international trade matters, commercial disputes, and complex business litigation to help clients evaluate and pursue potential claims arising from IEEPA tariffs. We work with companies to analyze import records, contractual arrangements, and financial impacts in order to determine the most effective legal strategy.

Our team also coordinates with Federal United Imports, an entity focused on IEEPA tariff-related claims and recovery efforts. Through this collaboration, we combine legal strategy with practical, process-driven support to assist clients in evaluating and pursuing available remedies.

Businesses We Advise

IEEPA tariffs affected a broad spectrum of market participants involved in international trade. Thompson LLP advises:

Importers of Record
Companies listed as the importer of record on U.S. Customs entry documentation that paid duties directly to U.S. Customs and Border Protection.

U.S. Businesses and Distributors
Companies that did not pay tariffs directly but absorbed increased costs through supply chain price adjustments or contractual obligations.

Foreign Manufacturers and Suppliers
Exporters that reduced pricing or otherwise absorbed tariff-related costs in order to maintain U.S. commercial relationships.

In many cases, the legal and commercial consequences of IEEPA tariffs extend beyond customs filings to contractual rights and obligations among business partners. Our team helps clients understand these dynamics and pursue appropriate remedies where available.

Tariff-related disputes often intersect with broader commercial relationships and long-term supply arrangements. Thompson LLP works with clients to evaluate legal options while preserving business objectives whenever possible.

Businesses seeking guidance on IEEPA tariff matters are encouraged to contact our team.