CFOs Steer Through Rising Complexity as Tariff Refund Wave Gathers Speed

The U.S. tariff refund process is proving more dynamic than many companies initially anticipated, with faster-than-expected claim processing now forcing CFOs to pivot from operational concerns toward increasingly complex financial, tax, and legal questions. 
What began with fears that the U.S. Customs and Border Protection (CBP) online refund portal might buckle under volume or stall due to documentation requirements has largely not materialised, according to accounting and customs advisers. Instead, the system is now moving claims from submission to approval and, in many cases, toward payment from the Treasury. 
“Companies are now seeing refund requests progress from submission to acceptance and, in many cases, into Treasury for payment processing,” said Lynlee Brown, partner in the global trade practice at Ernst & Young. She added that EY is tracking more than $500 million in claims, with some companies already receiving payments. 
CBP launched the portal on April 20 to handle refund claims linked to tariffs struck down by the U.S. Supreme Court in February. In a court filing dated May 12, the agency said it had processed $35.46 billion in refunds including interest as of May 11, with more than 15 million entries validated. 
The acceleration has surprised many advisers. “I wouldn’t even say surprised — shocked,” said Joshua Chananie, partner at Sax, noting that early expectations had been far more pessimistic regarding actual payouts. 
He also stressed that refunds are not limited to large multinationals. “Even small companies are starting to receive refunds,” he said. 
However, while the mechanics of filing appear to be working, execution quality remains a key challenge. Errors are increasingly tied to data mismatches between claims and original customs records rather than systemic issues. 
“Where there has been maybe a rejection, it’s been really around the data itself,” said Charles Clevenger, principal at UHY. “As long as those things match and companies are following the prescribed process, we’re not seeing any issues.” 
Even so, advisers caution that documentation discipline remains essential. “You weren’t required to file additional documentation with the claim, but you may need it to at least back up what you put into the system,” said James Robinson, principal at Armanino. 
Accounting and tax treatment become central issue 
As refunds begin flowing, attention is shifting to how companies should reflect them in financial statements. 
Some firms have already moved to recognise expected recoveries. Ford Motor Co. recorded a $1.3 billion benefit tied to potential tariff refunds in Q1, while General Motors cited roughly $500 million in expected refunds when raising guidance. 
Advisers say recognition depends on the level of certainty. “To the extent that you have some certainty about the amounts and what you’re getting, there is no preclusion from recording them,” said Ali Baydoun of UHY, warning that premature booking could lead to “over-promising and under-delivering.” 
Tax treatment adds another layer of complexity. In many cases, refunded tariffs may become taxable income depending on how they were originally treated. 
“If your business treated those tariffs as a deductible expense, then getting that money back can change things,” noted a tax advisory paper from Prado Tax Services. 
Legal disputes begin to surface 
Beyond finance and tax, litigation risk is also emerging. A growing number of lawsuits are challenging whether importers can retain refunds when tariff costs were effectively passed through to customers. 
Companies including FedEx, UPS, Costco and Lululemon face allegations of unjust enrichment and consumer protection violations tied to tariff reimbursements. 
“Litigation against importers is already underway,” said a report from Carter Ledyard & Milburn, arguing that customers may be entitled to share in refunds where they ultimately bore the cost. 
At the same time, procurement teams are being forced to reconstruct historical pricing and contract flows to determine how tariff costs were allocated. 
“It’s a bit of a mess,” said Focal Point CEO Anders Lillevik, highlighting the complexity of tracing cost pass-through across suppliers and customers. 
Despite the growing legal and financial complexity, advisers agree the CFO remains central to managing the process. 
“This is most definitely a CFO issue,” said Brown. “They don’t have to be in the weeds, but they do need to be closely involved.”