Tariff Task Force

Since the beginning of President Donald Trump’s second administration, global businesses across nearly every sector have been navigating a constantly changing tariff environment. In the most substantial shift to date, on Feb. 20, 2026, in the consolidated cases Trump v. V.O.S. Selections and Learning Resources, Inc. v. Trump, the Supreme Court ruled that the president may not use the International Emergency Economic Powers Act (IEEPA) as the legal basis to impose tariffs.

The end of IEEPA tariffs opens the door for new uncertainties. New tariffs have already been issued under Section 122 of the Trade Act of 1974. The decision leaves open the opportunity for businesses across a wide range of industries to file for refunds of the tariffs already paid, the process for which remains to be determined. While the recent opinion determined that the IEEPA tariffs cannot be upheld, it did not discuss the mechanism for seeking a refund. And the additional compliance, tax, and other strategic business considerations that ripple from this decision are still not fully understood.

Greenberg Traurig’s Tariff Task Force draws on the firm’s global platform to guide our clients through what comes next, whether that’s in the arena of future trade policy, tax, litigation, or M&A activity spurred by these global shifts.

Stay up to date on all of GT’s tariff insights here.

Our Capabilities

Our multidisciplinary team of trade attorneys, tax attorneys, litigators, and policy advisors provides high-level strategic counsel in critical areas:

• Tariff Recovery & Tariff Refund Litigation: With billions of dollars in IEEPA tariffs now ruled unauthorized, we are actively helping importers identify eligible entries, file protests with U.S. Customs and Border Protection (CBP), and pursue refund claims through the U.S. Court of International Trade (CIT).
• Tariff Compliance: While the IEEPA path has been restricted, the administration has already issued new tariffs under different authorities (such as Section 122 "Balance of Payments" surcharges or Section 301). We work to help you stay ahead of these shifts, so your supply chain can remain resilient to new enforcement measures, and respond when things change. This includes navigating the Administration’s trade agreements and impact on imports and duty payments.
• Supply Chain Strategies & Duty Mitigation: We provide high-level audits to mitigate exposure to remaining duties (such as Section 232 steel and aluminum tariffs) and future measures through:
  • Reviewing classification, valuation, and origin.
  • First Sale duty savings and valuation reduction.  
  • Utilization of Foreign Trade Zones and Bonded Warehouses.
  • Rigorous analysis of Country of Origin and Classification to pursue lowest legal duty liability.
• Considerations for Exporters to the United States: Non-U.S. suppliers of goods to the United States may wish to evaluate existing agreements and potential recourse with importers of record to seek to recover tariff refunds owed to the U.S. importer.
• M&A ( Implications: Parties negotiating purchase agreements may wish to specify which party is entitled to any IEEPA tariff refunds attributable to pre-closing periods (including any other possible refunds that may arise from new tariffs imposed under other statutory authority, to the extent such tariffs are subsequently ruled invalid).
• Tax Considerations (Multinational, Federal and State): 2025’s IEEPA tariffs created substantial transfer pricing issues for multinationals dealing with related party transactions. When these tariffs are refunded, a company’s decision as to how to allocate the refunds across their related entities in different countries, must be carefully thought out to minimize issues with the tax authorities in the various jurisdictions, each seeking to claim the refund as income for their country. We provide assistance with this analysis, seeking to minimize impact from a revenue authority inquiry.