March 11, 2026
Tariff & International Trade Resource
What Every Multinational Should Know About…Managing the Aftermath of the Supreme Court’s IEEPA Tariff Decision (Part III)
The importer of record is the entity that initially pays all tariffs and thus is the entity that would receive any IEEPA tariff refunds. Nonetheless, behind the scenes there often are a variety of mechanisms importers of record may have used to handle the often unexpected tariffs, including pushing back on suppliers for price concessions, using surcharges to pass along tariffs, or generally increasing price. In many cases, other parties may be looking to share any potential refunds.
