The recovery operating system
for the long-tail tariff economy.
A third-generation platform — purpose-built for Long-Tail Tariff (IEEPA) recovery — that manages the full claimant lifecycle: qualification, documentation, segmentation, legal routing, and recovery monitoring. One operating system. Every available pathway. Engineered to position each claimant to act immediately, regardless of how the legal landscape evolves.
The third generation of an operating system that has already paid clients.
Our team built the original infrastructure that powered our ERTC business. While most ERC firms vanished, we still actively service clients, receive approvals, and collect fees — because our systems were engineered for long-term lifecycle management, not short-term filing volume. This is the third generation of that platform, rebuilt for Long-Tail Tariff (IEEPA) recoveries and engineered to scale without significant added personnel.
End-to-end client lifecycle management.
Every action, document, communication, and status change is tracked inside the system. Nothing is ad hoc, nothing is lost, and nothing depends on heroic individual effort to keep moving.
- Referral-partner onboarding
- Claim intake & qualification
- Documentation collection
- Analysis & segmentation
- Case management & status tracking
- Automated client communications
- Legal routing by issue type
- Recovery monitoring & collections
One platform. Every step. Nothing falls through.
From referral to recovery, every claimant moves through the same auditable, instrumented workflow — and every action is captured.
Not every client follows the same path.
The platform routes each client by facts, industry, documentation, and legal strategy. Escalation is a function of what the file warrants — never a default.
- 01Simple RecoveryIOR voluntarily reimburses
- 02Negotiated ResolutionDemand letters & settlement
- 03CollectionsPursuit of unpaid obligations
- 04ArbitrationContractual disputes
- 05Individual LitigationSingle-claimant action
- 06Aggregated LitigationSimilarly-situated claimants combined
- 07Potential Class ActionWhere appropriate and certifiable
Not built around one law firm.
We are constructing a framework that engages multiple specialty firms by issue. Our current law firm helps us manage this framework today. The objective is the best legal team for each scenario — not one firm forcing every claim into one strategy.
Build the population.
The focus today is not litigation. It is identifying affected businesses, bringing them into the platform, collecting data, validating claims, segmenting claimants, and creating defensible recovery positions. The more validated claimants in the ecosystem, the stronger every recovery position becomes.
Positioned for every outcome.
Our responsibility is to put each client in the best position regardless of how the legal and political landscape evolves — direct reimbursement, administrative resolution, collections, arbitration, individual litigation, aggregated litigation, or class action. Each client is already documented, analyzed, organized, and positioned to move immediately.
We are building the infrastructure for the next three to five years.
Our framework routes every claim to the specialty firm and pathway it deserves.
Our third-generation platform was engineered to manage tens of thousands of claimants without significant added personnel.
Our team still services ERTC clients today. The same lifecycle discipline now underwrites long-tail tariff recovery.
This operating system was built so that whether the outcome is voluntary reimbursement, collections, arbitration, litigation, or class action — every claimant is organized, documented, and positioned to act immediately.
The six-level tariff recovery process
A structured pathway from analytics through interest recovery — every escalation triggered only by what your file warrants.
Analytics & Long-Tail Qualification
We review purchasing activity, supplier relationships, uploaded documents, and tariff exposure indicators to determine whether the client may qualify as a long-tail recovery candidate.
IOR Communication & Reimbursement Request
If the client is not the Importer of Record, we coordinate outreach to the actual IOR, supplier, distributor, or upstream importer to request reimbursement or cooperation.
Legal Demand Support
Where appropriate, qualified legal counsel may prepare attorney-led demand letters seeking reimbursement from the IOR or responsible upstream party.
Litigation Coordination
Independent litigation may be pursued through qualified legal counsel where appropriate. CCC coordinates documentation and workflow support but does not provide legal services.
Client Aggregation Database
Qualified clients may be organized into a client aggregation database for review by legal counsel for possible future class action or aggregated recovery opportunities.
Interest and Opportunity Cost Loss Recovery
We quantify statutory interest under 19 U.S.C. § 1505(b) and evaluate opportunity cost losses from capital tied up in overpaid duties, helping clients pursue full financial restoration beyond principal recovery.
You may qualify even if you were not the Importer of Record.
Many businesses paid tariff-related costs indirectly — through vendor pricing, distributor markups, imported components, equipment, materials, inventory, or finished goods. Direct importer status is not required to begin a review.
- You paid for imported goods, components, or materials — even indirectly
- Costs increased through vendor pricing, distributor markups, or supplier surcharges
- You source or purchase equipment, inventory, or finished goods
- You do not need an existing CBP relationship to complete an initial review
Upload your recovery documents securely.
After completing the eligibility intake, clients can upload supporting documents through a secure, password-protected portal connected to private encrypted storage.
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 (partner)
- CAPE Declaration · CSV · 9,999 entries / file — submitted by licensed CBP/customs partner
- 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 pathway analysis routed to qualified counsel for § 1514 protests and CIT‑level escalations where warranted.
Proprietary ACE/ITRAC ingestion, exposure modeling, and pre‑submission validation packaged for our licensed CBP/customs partners — only if a CAPE submission is warranted.
Monetize qualified refund entitlements at 50–60% of par today, perfected via UCC‑1.
CCC is not a customs broker or law firm. ACE/CAPE submissions and ABI filings are handled exclusively by our strategic licensed CBP/customs partners, only when a file warrants escalation.
5‑year lookback modeling. Substitution drawback opportunities routed to licensed partners for filing.
Retroactive USTR exclusion screening and PSC candidate identification, prepared for partner filing.
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/ITRAC analysis. Recoverable principal and interest quantified within 24 hours.
- 02Triage
Phase 1 entries prioritized. 80-day liquidation deadlines flagged for partner action.
- 03Route to Partner
Where a file warrants escalation, CCC packages the documentation and routes it to a strategic licensed CBP/customs partner who handles ACE/CAPE submission and ABI filing.
- 04Monitor & Recover
CCC coordinates recovery monitoring. ACH refunds typically deliver in 60–90 days after partner filing. 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 (filed by licensed customs partners) 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 (filing handled by our licensed CBP/customs partners, only when warranted)
ACE/ITRAC ingest. Quantified principal + interest estimate within 24 hours.
POA executed where warranted. Validated file packaged and routed to our licensed CBP/customs partner for ACE/CAPE submission and ABI filing.
Pre‑validation drives lower rejection rates. Partner monitors acceptance notices.
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 Platform & Recovery Pathways
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.
Start your recovery analysis in the CCC client hub.
Client intake, document collection, eligibility scoring, and case status all live in one secure hub. A senior member of our trade recovery desk reviews every submission and follows up within one business day.
- No-cost diagnostic — principal and accrued interest quantified
- Contingency-based engagement — no recovery, no fee
- Single source of truth for documents, status, and communications
Opens the CCC client hub at tariffcommand.compoundcapitalconnections.com.