The $166 Billion tariff
reimbursement window is open.
Compound Capital Connections is the national authority recovering unlawfully collected IEEPA duties — engineered with AI precision, delivered on contingency.
The largest customs refund event in U.S. history.
Following Learning Resources, Inc. v. Trump, the Supreme Court reasserted Congressional authority over import taxation — invalidating an entire regime of executive surcharges ab initio.
Major Questions Doctrine. Article I, § 8 reserves taxing power to Congress. IEEPA delegated none.
Senior Judge Eaton ordered nationwide reliquidation. CAPE deployed under 45‑day stay.
Unliquidated entries plus those liquidated within 80 days are immediately refundable.
Over 330,000 importers across 53 million entry summaries are theoretically eligible. The mechanism — the newly launched Consolidated Administration and Processing of Entries portal — places the burden of identification, validation, and filing entirely on the private sector.
Initial CAPE rollout data shows a 15% rejection rate, driven by data hygiene and discrepancies against the Automated Commercial Environment database.
- Enrollment
- ACE Portal + ACH refund registration
- Documentation
- CBP Form 7501 + IEEPA payment proof
- Filing
- CAPE Declaration · CSV · 9,999 entries / file
- Interest
- 19 U.S.C. § 1505(b) · IRS quarterly rates
- Payment
- ACH refund · 60–90 days from acceptance
Six recovery products. One execution platform.
Engineered for contingency pricing and institutional-grade execution.
Post‑SCOTUS CAPE declarations, § 1514 protests, and CIT‑level escalations.
Proprietary ACE ingestion. Pre‑filing validation reduces 15% rejection to under 5%.
Monetize refund entitlements at 50–60% of par today, perfected via UCC‑1.
Licensed brokers and trade attorneys oversee every ABI submission.
5‑year lookback. Substitution drawback recovers up to 99% of duties on exports.
Retroactive USTR exclusion capture and Post Summary Corrections.
From Fortune 500 to long-tail importers.
A serviceable obtainable market of $39B sits in the unregistered mid-market and small-business segments — historically ignored by Big Four and elite trade law.
Median claim $50M – $1B+. Co-counsel for Fortune 500 trade desks.
Median claim $250K – $5M. Vertical pods for autos, apparel, electronics.
Median claim $25K – $150K. Automated CAPE filing for small importers.
The white space is operational.
Customs brokers are designed for low-margin entry writing, not multi-year forensic audits. Law firms are constrained by the billable hour. The mid-market and long tail — collectively $71B in unaddressed recovery — are stranded.
Where the recoverable capital sits.
From ACE access to capital, in under 90 days.
- 01Diagnostic
Five-year ACE audit. Recoverable principal and interest quantified within 24 hours.
- 02Triage
Phase 1 entries fast-tracked. 80-day liquidation deadlines protected.
- 03File
AI-drafted CAPE declarations submitted via certified ABI within five business days.
- 04Recover
ACH refund delivered in 60–90 days. Optional factoring unlocks capital immediately.
The window is closing — and it is closing entry by entry.
Phase 1 CAPE eligibility expires at the entry level. Every day that passes, thousands of liquidated entries fall out of administrative reach forever. This is the highest-velocity refund opportunity in the history of U.S. trade law.
Three deadlines silently expiring
- 180‑day § 1514 protest window. Once an entry liquidates, you have 180 days. Miss it and the only path is CIT litigation.
- 314‑day final liquidation. CBP finalizes entries 314 days after entry. Final liquidation eliminates administrative refund options entirely.
- 5‑year drawback lookback. Substitution drawback rolls forward daily. Each week of delay forfeits the oldest week of recoverable exports.
Why early filers win disproportionately
- Interest from date of overpayment. Phase 1 filers capture interest from 2018–2025 deposits. Late filers capture only forward interest.
- Front‑of‑queue ABI processing. CBP throughput is finite. Early submissions liquidate in 60–90 days; late submissions stack into 9–12 month backlogs.
- Precedent capture. The first wave of CAPE rulings sets the substantiation bar. Early filers shape the standard; late filers comply with it.
From engagement to refund — typical Phase 1 cadence
ACE ITRAC ingest. Quantified principal + interest estimate within 24 hours.
POA executed. First CAPE batch transmitted via ABI to CBP.
Pre‑validation drives sub‑5% rejection. Acceptance notices begin landing.
ACH refund + accrued interest deposited. Factoring option closes in 5–10 days.
Answers for CFOs, controllers, and trade counsel.
Forty-plus questions on eligibility, process, pricing, compliance, and the AI infrastructure behind the filings.
The $166B Opportunity
Eligibility & Claim Types
The Filing Process
Pricing, Contingency & Factoring
Compliance & Risk
AI & Technology
Working With Compound Capital Connections
Request a tariff exposure audit.
No-cost diagnostic. Quantified principal and accrued interest within one business day.