You paid the tariffs. Every shipment that landed between early 2025 and early 2026 carried an extra layer of duty under the International Emergency Economic Powers Act, and you either absorbed it in your margins or passed it to your customers in higher prices. Then the Supreme Court struck those IEEPA tariffs down in February 2026 — and suddenly the money you already sent to Customs and Border Protection is claimable. One law firm's estimate puts the refund pool at about $166 billion across 53 million shipments from 330,000 importers.
Here is the catch that decides whether any of that money reaches you: only the importer of record can claim it, through CBP's CAPE portal, with documentation proving what you paid on which entries. Most small importers never built that audit trail. Their duties are buried in inventory costs across an ERP, a procurement inbox, and a broker's portal that were never designed to talk to each other. That gap is exactly what payments company Tipalti is aiming its new agentic AI at — AP software that can dig through your own payment history and assemble the refund case for you. Here is what the technology actually does, what the refund process demands, and how to book the money correctly when it lands.
What Tipalti Actually Built
Tipalti, the Foster City accounts-payable platform, has spent the last year rebuilding itself around agentic AI — software agents that carry out multi-step finance workflows instead of answering one question at a time. The work was funded in part by a $200 million growth financing round led by Hercules Capital in the fall of 2025, and it culminated in October 2026 with the launch of the Tipalti AP Agent, which the company says can manage the entire AP process end to end with human oversight, plus Model Context Protocol connections that pipe live finance data into enterprise AI tools.
The tariff angle sits on top of four specialized agents the company introduced earlier: a reporting agent that generates reports from natural-language prompts against invoice, procurement, and payment data; a tax-form agent that automates supplier onboarding and W-9 compliance; a purchase-request agent that drafts requests and routes approvals; and a payee-onboarding agent. Applied to tariffs, the pitch is simple. As Tipalti president Rob Israch put it, you can ask anything about a payment — its status, any detail from the bill — and drill down into the specifics that determine whether that payment falls under the Supreme Court decision. "Everything has to be faster now," he said, "and there needs to be an audit trail."
Tipalti is not alone. Freight forwarder Flexport shipped its own customs agent earlier this year that audits past entries for broker mistakes and refund opportunities, and large banks are upgrading corporate payments platforms for the same tariff-driven complexity. The pattern is clear: every vendor that touches your payables wants to be the tool that finds your refund. Whether any of them succeeds for you depends on the state of your records — which brings us to what CBP actually requires.
The Refund on the Table: IEEPA, CAPE, and Phase 1
Start with what is refundable. Only duties paid under IEEPA authority — the fentanyl and reciprocal tariffs the Court invalidated — are eligible. Section 301 China duties, Section 232 steel and aluminum duties, and antidumping and countervailing duties are untouched and not refundable. Note also that the administration imposed replacement tariffs under different legal authority, so new bills keep arriving even as the old ones become claimable. You are filing for the past, not the present.
CBP built a new system to handle the volume: the Consolidated Administration and Processing of Entries, or CAPE, launched inside the existing ACE portal on April 20, 2026. Phase 1 covers entries that are still unliquidated — CBP has not yet finalized them — plus entries liquidated within the last 80 days. Older, long-finalized entries fall outside this window, and analysts warn the process for anything at the edges will be slow and contested; if your entries are old, talk to your customs broker about the protest path rather than assuming CAPE will take them.
Three hard requirements apply no matter which phase you are in. First, only the importer of record can claim. If your customs broker filed on your behalf, you coordinate through them; if a carrier such as UPS or FedEx was the importer of record on your shipments, you cannot file directly at all. Second, refunds go only by ACH to the bank account on file in your ACE portal — no paper checks, no exceptions. Third, the U.S. Chamber of Commerce published a nine-step eligibility guide and warns frankly that determining whether your business qualifies, and what to do next, is challenging. Plan for months, not days, and expect statutory interest to accrue while you wait.
There is also a parallel track worth knowing about. If you re-exported imported goods, or destroyed them, the decades-old duty drawback program refunds up to 99% of the duties through CBP Form 7551 filed in ACE, with claims allowed up to five years after import. Drawback is a separate process from the IEEPA refunds, with its own paperwork — but it draws on the same underlying records, so everything below helps both claims at once.
Why Claiming Is a Bookkeeping Problem, Not a Form Problem
The CAPE declaration is just the last step. Everything before it is reconciliation work: matching entry summaries (CBP Form 7501) to the duties you actually paid, confirming tariff classifications and country-of-origin data per entry, and tying it all back to your own invoices and payment records. Trade analysts have been blunt that most companies lack the data hygiene for this — the proof lives in internal ERP, procurement, and logistics systems that were never designed for audit-grade traceability, and brokers can only file what you can substantiate.
For a small importer, the failure modes are concrete:
- You are not the importer of record and do not know it. Small sellers who let a supplier, freight forwarder, or express carrier handle customs often discover the entry names someone else. No importer-of-record status, no claim — find out now, from your entry summaries, not from assumptions.
- Your duties have no paper trail in your own books. If every shipment's duty was folded silently into inventory cost with no entry number attached, reconstructing which dollars were IEEPA duties — versus Section 301 or freight — becomes archaeology. The Chamber's nine steps assume you can identify your IEEPA payments; many businesses cannot yet.
- Your broker relationship is one-directional. Brokers file entries, but the classification, valuation, and origin data originates with you. A broker cannot conjure a refund claim from their portal alone if your purchase records disagree.
- You assume the refund is automatic. It is not. Every dollar requires a declaration, documentation, and patience — and analysts caution that the government may contest claims where importers passed tariff costs through to customers, so keep your pricing records too.
This is the job the AI agents are actually selling: not filing the form, but assembling the evidence. A reporting agent that can answer "show me every 2025 payment tied to shipments from this country of origin, with amounts and entry references" turns weeks of spreadsheet archaeology into an afternoon — provided the underlying data exists to be searched.
What the AI Agent Can and Cannot Do for You
Be clear-eyed about where automation helps and where it stops. Here is the honest split.
What it can do. An AP agent with access to your invoices, purchase orders, and payment history can find every tariff-bearing payment without you remembering which supplier invoice went with which shipment. It can group payments by supplier, country of origin, and time period; pull line-item details from bills on demand; generate the documentation pack your broker needs; and maintain the audit trail Israch emphasized — who paid what, when, against which entry. If your duties were tracked in a dedicated account or tagged per shipment, the agent's output is close to filing-ready.
What it cannot do. It cannot make you the importer of record. It cannot open your ACE portal account, enroll your bank for ACH refunds, or sign your CAPE declaration. It cannot decide whether an old entry belongs in CAPE or needs a protest filing, and it cannot fix records that were never kept — if three years of duties sit in one unlabeled COGS balance, a human still has to reconstruct them, ideally with the broker's entry data. And Tipalti itself positions the AP Agent as operating with human oversight, which is the right framing: let it do the digging, but review the claim package before anything goes to CBP.
The practical takeaway: an AI agent multiplies the value of clean records and cannot create them. If you import today, start tagging every shipment's duties with its entry number and tariff authority now — in a subaccount, a class, or even a disciplined spreadsheet. The next refund, drawback claim, or rate change will reward you the same way.
How to Book the Refund When It Lands
This is where small importers most often go wrong, and the mistake is expensive in the other direction: treating recovered duties as new revenue. It is not revenue. The duty was a cost — capitalized into your inventory or expensed when paid — and the refund reverses that cost. Booking it as sales overstates your revenue, distorts your margins, and can double-count income you already recognized when you sold the goods.
The correct entry depends on where the original duty sits:
- Goods already sold. The duty flowed into cost of goods sold when the sale happened. Reduce COGS in the period you receive the refund: debit Cash, credit COGS. Keep it a visible separate line rather than netting it invisibly, so your margins stay honest and the one-off windfall does not masquerade as improved operations.
- Goods still on hand. The duty is still sitting in your inventory valuation. Reduce the inventory account instead: debit Cash, credit Inventory. Your carrying value drops to what the goods truly cost you.
- The interest portion. CBP pays statutory interest on refunds. That interest is interest income, not a cost recovery — book and tax it separately.
On taxes, the same logic applies. Recovered duties reduce your costs, which raises taxable income in the year received — the tax-benefit rule in plain clothes. Set aside a slice of every refund for the tax bill it creates, and confirm the timing with your CPA, since larger businesses may need to book a receivable before cash arrives under GAAP's loss-recovery rules.
Here is the full cycle in a plain-text ledger, from purchase through sale to refund. Duties of $8,450 were capitalized into a $50,850 inventory buy, the goods sold, and the IEEPA refund arrived months later by ACH:
2026-05-20 * "Q2 inventory buy, IEEPA duties capitalized into cost"
Assets:Inventory:Imported-Goods 50850.00 USD
Liabilities:Accounts-Payable
2026-09-30 * "Q2 imported goods sold"
Expenses:Cost-Of-Goods-Sold 50850.00 USD
Assets:Inventory:Imported-Goods
2026-11-09 * "IEEPA tariff refund received, CBP ACH"
Assets:Checking 8450.00 USD
Expenses:Cost-Of-Goods-Sold -8450.00 USDThe last entry is the whole lesson in three lines: cash in, COGS down, no revenue touched. If the goods were still in your warehouse, that credit would go to Assets:Inventory:Imported-Goods instead. Either way, the refund stays traceable to the shipment that earned it — which is precisely the audit trail CBP, your broker, and any AI agent you deploy all want to see. If you track inventory this way, the Beancount documentation covers cost-basis handling in more depth, and you can watch the refund land as a one-month dip in COGS on your Fava dashboard rather than a mysterious margin jump.
Your Next Three Moves
First, confirm you are the importer of record. Pull your entry summaries and check whose name is on them; if it is your broker, loop them in now, and if it is a carrier, find out what claiming path — if any — is available to you before spending another minute on paperwork.
Second, get your CBP house in order. Open an ACE portal account if you do not have one, enroll your bank account for ACH refunds, and download every entry summary and duty-payment record you can reach. At the same time, open a dedicated tracking account for import duties in your books and tag each payment with its entry number going forward, so the next claim assembles itself.
Third, build the packet and file. Gather entry summaries, commercial invoices, proof of duty payment, and classification and origin records for your Phase 1 entries — using your AP software's search and reporting, AI-assisted or not — and submit the CAPE declaration. For older entries, ask your broker about the protest route before any deadline passes you by.
About $166 billion is on the table, but CBP will not come looking for you. The importers who recover their duties will be the ones whose books can prove what they paid, shipment by shipment. Make yours one of them.
