If your business imports goods, you’ve probably heard about the ongoing debate over certain International Emergency Economic Powers Act (IEEPA) tariffs and the possibility of tariff refunds. After the Supreme Court struck down certain IEEPA tariffs in February 2026, U.S. Customs and Border Protection (CBP) began processing refunds through a system called CAPE. These refunds were welcome news for many businesses dealing with higher import costs, but now many importers are asking: Are these tariff refunds taxable? In many cases, they can be, but the answer depends on how you originally treated the tariff payments for tax purposes.
Below, we’ll explain how tariff refunds and taxes work together, including what counts as taxable income, how cost of goods sold (COGS) and inventory come into play, interest income, and what you may need to report on your tax return.
Note: The legal status of some IEEPA tariff refunds is still evolving. Ongoing court appeals and CBP guidance could affect refund eligibility, timing, or filing procedures for some importers. This article focuses on the tax treatment of refunds that have already been received (or that you become entitled to receive).
At a glance
- Tariff refunds can be taxable. If you deducted the original tariff payments through COGS, depreciation, or another business expense, the refund is generally taxable.
- Inventory still on hand is the big exception. If unsold goods remain in stock, the refund usually reduces inventory costs rather than creating immediate taxable income.
- Interest paid with the tariff refund is separate income. Some refunds include interest paid by CBP. This interest portion is generally taxable as ordinary income in the year you receive it.
- You typically report the tax impact in the year of recovery, not by amending old returns; however, your accounting method (cash vs. accrual) will affect the timing.
- Good records matter. Tie each refund to the entries, products, and tax years where you originally claimed the duty as a cost.
Tariff refund terms explained
If you’re new to the tariff refund process, here are a few terms you’ll see throughout this article:
- CBP (U.S. Customs and Border Protection): The agency that collects duties and administers the tariff refund program.
- ACE and CAPE: CBP’s online systems used to manage import information and certain tariff refund claims.
- Importer of record: The business or individual legally responsible for the imported goods and duty payments.
Now that we have all the definitions, let’s look at how tariff refunds are treated for federal income tax purposes.
Are tariff refunds taxable income?
Often, yes, at least in part. The key question is whether the original tariff payments reduced your taxable income in a prior year. If they did, some or all of the refund may be taxable under the tax benefit rule (explained in the next section) and may need to be included in gross income in the year you received it.
The tax benefit rule explained
The tax benefit rule (Section 111 of the Internal Revenue Code) is why many tariff refunds are taxable.
Here’s the basic idea: If you claimed a deduction for an expense in a prior year and that deduction lowered your tax bill, the IRS generally expects you to report any later refund of that expense as income. You don’t usually get to keep both the tax break and the refund.
In practice, it works like this:
- You deducted an expense in a prior year.
- That deduction reduced your taxable income (or increased a loss you later used).
- This year, you received a refund related to that expense.
- You include all or part of the refund in this year’s income.
This same concept applies to many IEEPA tariff refunds. If the original tariff payments reduced your federal tax liability, the refund may be taxable. If the duties never provided a tax benefit in the first place, the refund may not be taxable.
Note: The tax benefit rule doesn’t just apply to IEEPA tariff refunds. The IRS uses the same approach whenever a business recovers costs it previously deducted. For example, similar principles have applied to certain customs duty, anti-dumping duty, and countervailing duty refunds.
Tariff refunds vs. ordinary business income
A tariff refund isn’t the same thing as making a sale. Instead, you’re usually recovering a cost your business previously paid. That distinction matters because the tax treatment depends on how the original tariff payments were reported.
Tariff refund tax treatment: How tariff refunds affect COGS and inventory
For many importers, tariff payments are included in inventory costs and are eventually included in COGS when products are sold. So, whether the inventory connected to the refund has already been sold determines whether the refund creates taxable income today or affects your taxes later.
Tariff refunds taxable treatment by situation
Here’s a quick breakdown of the tax implications of tariff refunds by situation:
| Situation | Typical federal tax treatment | When it shows up |
|---|---|---|
| Duties on inventory you already sold | Taxable income (tax benefit rule) | Year refund is received (or fixed, for accrual businesses) |
| Duties on inventory still on hand | Reduce inventory cost; not immediate income | Lowers COGS as goods are sold |
| Duties capitalized into equipment | Reduce asset basis (may affect depreciation and future tax deductions) | Future depreciation deductions |
| Original duty did not reduce federal tax | May be excluded from income | Depends on facts; for example, if the deduction gave little or no tax benefit (maybe the business was already at a loss), the refund may not be taxable |
| Statutory interest on tariff refund | Ordinary income | Year interest is received |
Below, we explain some of these scenarios in more detail.
Tariff refunds COGS example: when the related inventory has already been sold
Say you imported goods, included the duties in the inventory cost, sold the products, and then subtracted those tariff costs as COGS. In this situation, you’ve already gained a tax benefit from the tariffs.
Now that you received a tariff refund, the portion related to the sold inventory is generally treated as income in the year you receive it (or in the year your right to the refund is fixed, if you use accrual accounting). Typically, you don’t need to go back and change your old COGS numbers on previous tax returns.
Example
- Your company paid $50,000 in IEEPA duties on the inventory you imported in 2025.
- You sold all that inventory before filing your 2025 return and included the duties in COGS.
- In 2026, CBP refunds you $50,000.
Under the tax benefit rule, you include the refunded amount in income because you already received a tax benefit from deducting the duties. If the full $50,000 deduction reduced your taxable income in 2025, the full $50,000 refund would typically be taxable in 2026.
However, if your business was operating at a loss or otherwise did not receive the full tax benefit of the deduction, all or part of the refund may be excluded from income.
Tariff refunds inventory costs example: when inventory is still on hand
If the imported goods have not been sold yet, you typically haven’t received a tax benefit from the duty portion still sitting in inventory. In this situation, a tariff refund usually reduces the cost basis of your inventory instead of creating immediate taxable income.
That means future COGS will be lower as you sell the goods, which spreads the tax effect over time rather than hitting you in one lump sum.
Example
- You paid $10,000 in IEEPA duties on products that are still in your warehouse when CBP issues a $10,000 refund.
- Because the goods have not yet been sold, you likely have not received a tax benefit from the duties through COGS.
Instead of reporting the refund as income in this scenario, you would typically reduce the inventory’s cost basis by $10,000. When you later sell those products, your COGS will be lower, which may increase your taxable income in that future tax year. This effectively postpones the tariff refund taxable impact until the inventory is sold.
Mixed inventory: part sold, part on hand
If some units are sold and some remain, you would generally split the refund between:
- Sold portion: Income in the year of recovery
- Unsold portion: Inventory basis adjustment
Your entry-level records from customs and your inventory system should help you allocate the refund. If you use a broker or third-party logistics provider, confirm who received the refund and how it was passed through to you.
Tax tip: Businesses with complex supply chain operations may need additional documentation to allocate refunded tariffs between sold inventory and inventory still on hand.
If you’re splitting a refund between sold and unsold inventory or trying to match CBP entry records to your books, you don’t have to figure it out alone. TaxAct Xpert Assist® connects you with credentialed tax experts who can help answer questions as you file.*
Is interest on tariff refunds taxable?
Yes. CBP has stated that tariff refunds can include interest on unlawfully collected duties. That interest is not a return of your old deduction — it’s new income.
The IRS generally treats this interest as ordinary income for federal income tax purposes. Depending on where your business operates, the interest may also affect your state income tax calculations.
Tax tip: Keep the duty and interest amounts separate in your books, as they may need to be reported differently on your return.
State income tax on tariff refunds
Many states follow federal treatment for business recoveries, but state conformity rules can vary. In some states, a federally taxable tariff refund may also be includible in state business income. In others, inventory basis adjustments or different rules may produce a different result. If your business files in multiple states, it may be worth confirming how each state treats duty recoveries before you finalize your books.
Tariff refund accounting treatment: cash vs. accrual
Your accounting method affects when the tariff refund shows up on your tax return, even when the same tax principles apply.
Cash-basis businesses
If you use the cash method (common for many small businesses), you generally recognize the taxable portion of a tariff refund when you receive the payment.
This is usually the simpler scenario because, in most cases, you report the taxable portion of the refund when the money arrives. Just be aware that approval and payment don’t always happen at the same time, so there may be a delay between filing a refund claim and seeing the cash hit your account.
Accrual-basis businesses
If your business uses the accrual method of accounting, you may need to report a tariff refund as income once you’re entitled to receive it (also referred to as the year your right to the refund is “fixed”), even if the money hasn’t hit your bank account yet.
For example, if CBP approves your refund in one tax year but the deposit doesn’t arrive until the next, you may still need to recognize the income before you actually receive the cash.
The IRS discusses accounting methods in Publication 538, Accounting Periods and Methods. If your business recently changed accounting methods or follows specialized inventory accounting rules, it may be helpful to speak with a tax professional about how a large tariff refund should be reported.
What to do when you receive a tariff refund
A tariff refund can be a great boost to cash flow, but don’t just toss the paperwork in a drawer and forget about it. Follow the five steps below to help you report the refund correctly.
Step 1: Confirm what you are getting back.
Start by figuring out exactly what you received and what it relates to.
Record:
- Total duty refunded to you
- Interest paid with the refund
- Which entry numbers and import dates tie to the payment
- Whether the refund went to you as the importer of record or through a broker
Depending on the type of refund claim, you may also want to note the liquidation status of the affected entries, as CBP’s refund procedures can vary for liquidated and unliquidated entries. CBP’s IEEPA duty refunds page explains the CAPE Phase 1 requirements.
If you worked through customs brokers or other professional services providers, verify whether the refund was sent directly to you or routed through a third party.
Step 2: Match the refund to your tax records.
Next, connect the refund to the way the original duties were reported on your tax return.
Ask:
- Did we deduct these duties through COGS?
- Was related inventory sold or still on hand?
- Did we capitalize duties into fixed assets?
- Did the original deduction actually reduce our federal tax?
- Were any of these entries subject to transfer pricing adjustments or other valuation changes?
Your answers to these questions will determine whether you have immediate income, an inventory adjustment, or a basis change.
Step 3: Update your books before tax time.
Don’t wait until March to think about this! When the refund hits:
- Record the duty portion based on your inventory and tax analysis.
- Record interest as income.
- Adjust inventory balances for unsold goods.
- Adjust asset basis for equipment (if applicable).
As with most things, solid bookkeeping now makes tax filing much less painful later.
Step 4: Report on the right business return.
Where the refund gets reported on your return depends on your business entity type:
| Business type | Tax form(s) | Where you typically report a tariff refund |
| Sole proprietor or single-member LLC | Schedule C (Form 1040) | Taxable tariff refunds may be reported as other business income or reflected through a COGS adjustment, depending on how the duties were originally treated. |
| C corporation | Form 1120 | Tariff refunds are generally reported as part of the corporation’s income and expense reporting. |
| S corporation | Form 1120-S | Tariff refunds are generally reported at the business level and passed through to shareholders as part of the entity’s tax reporting. |
| Partnership or multi-member LLC taxed as a partnership | Form 1065 and Schedule K-1 (Form 1065) | Tariff refunds are generally reported by the partnership and allocated to partners through Schedule K-1. |
The exact reporting treatment depends on how you originally handled the tariff payments and whether the refund relates to sold inventory, unsold inventory, or business assets. Remember that taxable duty recoveries and interest may also be reported differently, so it’s important to keep those amounts separate in your books.
Tax tip: Not sure where a tariff refund lands on your return? TaxAct® business products can walk you through the filing questions for your entity type step by step (for self-employed filers, see TaxAct Self-Employed). If you’re not sure which return fits, start with which business return you should file.
Step 5: Plan for tax on the refund.
If you have tariff refund taxable income this year, you may owe more than you would typically pay in a quarter, especially if you have an accrual-basis company that must recognize income before receiving it.
Consider updating your estimated tax payments, so you are not caught off guard, as underpayment can lead to IRS penalties and interest.
If you need help, TaxAct walks you through business income and expenses with plain-language questions, so you’re not guessing where to report refund income on your return.
Special situations for importers
Not every tariff refund will fit neatly into the inventory examples mentioned earlier. Below, we’ve highlighted a few situations where the rules can get more complicated.
Duties on business equipment and fixed assets
Some importers paid IEEPA tariffs on machinery, fixtures, or other depreciable assets, not on resale inventory. If these duties were added to the asset’s tax basis and are being depreciated, a refund typically lowers the basis rather than producing immediate income (which may lead to reduced depreciation deductions in the future). In some cases, reducing the basis can trigger depreciation recapture rules, where it may be wise to consult a tax professional.
Pass-through entities and the QBI deduction
If you operate through an S corporation, partnership, or sole proprietorship, you may claim the qualified business income (QBI) deduction on eligible business income. Recovery of tariff duties related to business COGS might still qualify as business income for QBI, but interest may be treated differently depending on how it is classified.
The rules can get technical fast, so just make sure to keep your duty recoveries and interest separate to help you report everything correctly when filing your return.
Tax tip: If you want a second set of eyes while you work through it, TaxAct Xpert Assist can connect you with a credentialed tax expert during filing.*
Buyers who did not import directly
If your business purchased imported goods from a supplier instead of importing them directly, the refund process may look very different. In some cases, you might receive a vendor credit or price adjustment rather than a refund from CBP.
The same tax principles apply, but your documentation will look different, so make sure you know whether you are recovering your own costs or receiving a price adjustment from a supplier.
FAQs
The bottom line
If your business receives a tariff refund, the next step is figuring out the tax considerations. Tariff refunds and taxes don’t follow one simple rule — what matters is how the original duties were treated for tax purposes and whether the related goods have already been sold.
As always, TaxAct can help you report business income, expenses, and refund reporting when you file, so you can spend less time decoding tax rules and more time running your business. When you’re ready, explore TaxAct online tax filing for your entity type, and keep an eye on important tax dates and deadlines so estimated payments don’t sneak up on you.
This article is for informational purposes only and not legal or financial advice.
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* TaxAct® Xpert Assist is available as an added service to users of TaxAct’s online consumer and SMB 1120-S and 1065 products. Additional fees apply. Unlimited access refers to an unlimited quantity of expert contacts available to each customer. Service hours limited to designated scheduling times and by expert availability. Some tax topics or situations may not be included as part of this service. Review of customer return is broad, does not extend to source documents, and is not intended to be comprehensive; expert is available to address specific questions raised by customer. View full TaxAct Xpert Assist terms and conditions.
Citations
Internal Revenue Service. “About Form 1040, U.S. Individual Income Tax Return.” IRS, www.irs.gov/forms-pubs/about-form-1040. Accessed 1 June 2026.
Internal Revenue Service. Publication 538 (01/2022), Accounting Periods and Methods. IRS, www.irs.gov/publications/p538. Accessed 1 June 2026.
Internal Revenue Service. “Qualified Business Income Deduction.” IRS, www.irs.gov/newsroom/qualified-business-income-deduction. Accessed 1 June 2026.
Internal Revenue Service. “Section 111.—Recovery of Tax Benefit Items.” Revenue Ruling 2019-11, 2019, www.irs.gov/pub/irs-drop/rr-19-11.pdf. Accessed 1 June 2026.
TaxAct. “Form 1120 Filing Guide: Corporate Tax Return & Schedules Explained.” TaxAct Blog, 26 Jan. 2026, https://blog.taxact.com/guide-to-1120-form/.
TaxAct. “Form 1120-S Instructions: How to File IRS 1120-S for S Corps.” TaxAct Blog, 11 Feb. 2026, https://blog.taxact.com/guide-to-1120s-form/.
TaxAct. “How to Calculate and Make Estimated Tax Payments.” TaxAct Blog, 3 Sept. 2025, https://blog.taxact.com/calculate-and-make-estimated-tax-payments/.
TaxAct. “Schedule C: How to Report Business Income & Expenses.” TaxAct Blog, 5 Feb. 2026, https://blog.taxact.com/schedule-c-business-income-expenses/.
TaxAct. “What Is the QBI Deduction and How Does It Work?” TaxAct Blog, 20 Aug. 2025, https://blog.taxact.com/what-is-qbi-and-how-does-it-work/.
U.S. Customs and Border Protection. “International Emergency Economic Powers Act (IEEPA) Duty Refunds.” U.S. Customs and Border Protection, www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds. Accessed 1 June 2026.
TaxAct. “File Self-Employment Taxes.” TaxAct, www.taxact.com/taxes-online/file-your-own-taxes/self-employed-tax-filing.
TaxAct. “Which Business Return Should I File?.” TaxAct Support, www.taxact.com/support/1406/2024/which-business-return-should-i-file.
Ponder, Meghen. “How IRS Penalties and Interest Work.” TaxAct Blog, 2 June 2026.
TaxAct. “Depreciation – Recapture of Excess Depreciation.” TaxAct Support, www.taxact.com/support/14588/depreciation-recapture-of-excess-depreciation.
TaxAct. “Expert Tax Help – From Simple Questions to Full Filing Support.” TaxAct, www.taxact.com/tax-xpert-assist.
Ponder, Meghen. “Important Tax Dates and Deadlines in 2026.” TaxAct Blog, 9 Jan. 2026.