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CIT Rules Section 122 Tariffs Unlawful – Yet Most Importers Still Affected

On May 7, 2026, the U.S. Court of International Trade (CIT) ruled against the imposition of 10% temporary global tariffs by the administration under Section 122 of the Trade Act 1974 by calling it “unlawful.” In a split 2-1 decision, the court found that the administration failed to meet the strict legal requirements of Section…

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Time for Importers to Take Action: April 20 Starts the IEEPA Tariffs Refund Process

It’s finally time for importers to take the first step in claiming IEEPA tariff refunds. This long-awaited move forward comes after the U.S. Supreme Court deemed IEEPA tariffs imposed by the president unconstitutional and the Court of International Trade issued a ruling for Customs and Border Protection (CBP) to refund duties imposed under IEEPA tariffs…

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Essential FAQs on 83(b) Election for Non‑U.S. Taxpayers

Receiving equity from a U.S. company if you are not a U.S. citizen or resident alien can raise questions about how and when that equity is taxed in the United States. For U.S. tax purposes, these individuals are generally referred to as “nonresident aliens” or “non-U.S. persons.” One common consideration is whether to file an…

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Section 962 Election Considerations After 951A and 250 Changes

Beginning with tax years after December 31, 2025, changes to Sections 951A and 250 significantly alter the tax landscape for U.S. individuals considering a Section 962 election. The One Big Beautiful Bill Act, commonly referred to as the OBBBA or OB3, replaces the Global Intangible Low-Taxed Income (GILTI) regime with Net CFC Tested Income (NCTI)…

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CIT Suspends Immediate IEEPA Tariff Refunds Order to Allow Time for New CBP 7-Step ACE Refund Process

On March 6, 2026, the U.S. Court of International Trade (CIT) held a closed conference to discuss the government’splan for administering the International Economic Emergency Powers Act (IEEPA) tariff refunds. The CIT paused its earlier order for immediate IEEPA tariff refunds to allow U.S. Customs and Border Protection (CBP) time to account for the limitations…

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Three Options to Pursue a Refund on IEEPA Tariff Over-Payments

UPDATE:Following the March 4, 2026, ruling from the Court of International Trade directing CBP to refund duties imposed under IEEPA tariffs, CBP has released new guidance. Read more here for the latest updates, including CIT’s decision to suspend immediate refunds in order to allow CBP’s new refund process to be put into place. On March…

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