The Supreme Court struck down IEEPA tariffs on $166B in annual imports. That created a recovery opportunity for 330,000 U.S. importers. It also created a revenue opportunity for every professional who touches those importers — customs brokers, trade attorneys, freight forwarders, and accounting firms.
This article breaks down the economics. Not theory — actual fee structures, engagement values, and portfolio projections you can model against your own client base.
Engagement Types and Fee Structures
Every IEEPA recovery engagement involves up to three revenue-generating activities. Not every client triggers all three, but most trigger at least two.
1. Prior Disclosure and Protest Filing Fees. For entries within the 180-day protest window under 19 U.S.C. §1514, the engagement involves preparing and filing Post Summary Corrections (PSCs) and formal protests through the ACE system. Filing fees range from $7,400 to $13,875 per client depending on entry count and complexity. This is the bread-and-butter revenue stream — predictable, repeatable, and billable at engagement start.
2. Referral Fees on Claim Assignments. Some importers prefer immediate liquidity over waiting 6-12 months for CBP to process protests. Claim assignment — selling the right to collect to a third-party funder — pays the importer a percentage of the claim value upfront. Partners who refer clients into claim assignment structures earn a percentage of the closed transaction. See tariffbuyouts.com for how these work. Referral fees on claim assignments are percentage-based and paid at closing.
3. Referral Fees on CIT Litigation. Entries outside the 180-day window require Court of International Trade litigation. Attorneys handling CIT cases work on contingency (20-33% of recovery) or hybrid models. Referring professionals earn a referral fee on litigation engagements they originate. These are the highest per-engagement fees but the longest cycle times — 18-24 months.
Single Client Examples
Example A: Mid-Size Importer — $500K Exposure
A furniture importer bringing in $3.2M annually from China paid $487,000 in IEEPA surcharges over 16 months. Their entry data shows 47 entries with HTS 9903.01 codes. Of those, 38 are within the 180-day protest window and 9 are outside it.
Revenue from this single client:
| Activity | Revenue |
|---|---|
| PSC + protest filing fees (38 entries) | $9,200 |
| Referral on claim assignment (if client opts in) | Percentage of assignment value |
| Referral on CIT litigation (9 entries, ~$93K) | Referral fee on contingency engagement |
The filing fees alone make this client profitable. The claim assignment and CIT referral fees are upside.
Example B: Large Importer — $2.3M Exposure
An electronics distributor importing $14M annually paid $2.3M in IEEPA surcharges across 183 entries. All 183 entries are within the protest window. This is a high-value, single-stream engagement.
| Activity | Revenue |
|---|---|
| PSC + protest filing fees (183 entries) | $13,875 |
| Referral on claim assignment ($2.3M claim) | Percentage of assignment value |
No CIT referral here because all entries are within the window. But the claim assignment referral on a $2.3M claim is substantial. This is the kind of client that justifies the entire partner program for a small brokerage.
Portfolio Example: 35 Clients Over 6 Months
A mid-size customs brokerage with 120 active importer clients screens all of them. Of those, 35 have material IEEPA exposure (over $50K each). Average exposure per client: $420,000.
Filing fees across 35 clients at an average of $9,800 per engagement: $343,000 in filing fee revenue over 6 months. That number is conservative — it assumes no claim assignment referrals and no CIT litigation referrals.
Add claim assignment referrals on even 10 of those 35 clients and the total rises materially. Add CIT referrals on the subset with entries outside the window and you are looking at an additional revenue layer that compounds over the following 12 months.
Revenue by Professional Type
Each partner type captures revenue differently. The structure of the fees favors different practice models.
Customs Brokers: Highest Total Volume
Brokers have ACE access, entry-level data, and the largest client bases. A typical mid-size brokerage serves 80-200 importers. If 40% have IEEPA exposure, that is 32-80 engagements.
Brokers earn on every activity: filing fees (they can prepare the PSCs themselves or refer out), claim assignment referrals, and CIT litigation referrals. Volume is the broker’s advantage. A customs broker with 50 affected clients generates more total revenue than any other partner type with the same effort.
Trade Attorneys: Highest Per-Engagement Value
Attorneys handle CIT litigation directly, earning contingency fees of 20-33% on recoveries. A single CIT engagement on $500K in outside-window entries at 25% contingency yields $125,000 in legal fees. No other partner type earns that per engagement.
The tradeoff: attorneys handle fewer engagements because CIT cases require significant legal work. But the per-engagement economics are exceptional. A trade attorney who originates 8-12 CIT engagements in year one builds a substantial practice line.
Freight Forwarders: Highest Margin Per Hour
Forwarders do not file PSCs or litigate. Their role is screening and referring. That means their time investment per client is minimal — 15-20 minutes to identify exposure and submit for assessment.
The referral fees forwarders earn are lower per engagement than what brokers or attorneys earn. But measured against time invested, the margin per hour is the highest of any partner type. A freight forwarder who screens 40 clients in a week invests roughly 12 hours and generates referral fees on every engagement that closes.
Accounting Firms: Dual Revenue Stream
Accountants earn referral fees on tariff recovery engagements they originate. They also earn advisory fees on the financial reporting implications — ASC 450-30 gain contingency analysis, COGS adjustments, and tax planning around the refund. The advisory work is billed at standard hourly rates on top of referral income.
The Compounding Effect Over 12 Months
Month 1-3 revenue comes from filing fees. These are earned at engagement start and represent immediate cash flow. Filing fees across a portfolio of 35 clients produce $300K-$350K in this window.
Month 4-8 revenue adds claim assignment referral fees as importer clients opt for early liquidity. Not every client takes the assignment, but those who do generate referral income at closing.
Month 8-18 revenue adds CIT litigation referral fees. These are the longest-cycle payments but also the largest per-engagement. They begin arriving as early CIT cases settle or win summary judgment.
The compounding pattern means a partner who starts screening clients today sees three distinct revenue waves over the next 18 months. Partners who wait miss the filing fee wave entirely as protest windows close, and compete for the remaining CIT referrals in a crowded market.
Modeling Your Own Portfolio
Pull your client list. Count the importers sourcing from China, Hong Kong, and countries subject to IEEPA surcharges. Estimate that 35-45% of those importers have material IEEPA exposure (over $50K). Multiply by $9,800 average filing fees for the conservative case.
For a brokerage with 100 active importers: 40 affected clients x $9,800 = $392,000 in filing fee revenue alone. That excludes claim assignment and CIT referral fees entirely.
For a law firm with 25 importer clients: 10 affected clients with CIT exposure averaging $300K per client at 25% contingency = $750,000 in legal fees over 18 months.
For a freight forwarder with 60 importer relationships: 25 affected clients generating referral fees at engagement close across filing, assignment, and litigation streams.
The math works at every scale. The question is timing. Revenue per engagement does not change much between March and July, but the number of available clients drops sharply as competitors move. For deeper analysis of the competitive dynamics, see tariffresolution.com and our competitive window analysis. For the deadline urgency driving that timeline, see the 180-day deadline analysis.
Run the numbers on your own book. Direct clients to the IEEPA Refund Checker for a quick preliminary eligibility screen, then request an assessment for your first 5 clients and see the actual figures.
FAQ
Q: Are referral fees paid upfront or on recovery? A: Filing fees are earned at engagement start — when the client signs the authorization and work begins. Claim assignment referral fees are paid at closing. CIT litigation referral fees are paid when the case resolves. Each stream has a different timeline, which is why portfolio diversification across many clients smooths cash flow.
Q: What is the minimum client exposure that makes an engagement worthwhile? A: We process engagements at all exposure levels, but the economics are strongest above $50K in total IEEPA surcharges. Below $25K, the filing fees still apply but the referral upside is limited. Above $200K, every revenue stream activates and the engagement is highly profitable for all parties.
Q: How does chinatariffrefund.com fit into the referral structure? A: China-specific recoveries are the largest segment — roughly 70% of all IEEPA exposure by dollar value comes from China-origin imports. The chinatariffrefund.com platform handles importer-facing intake for China-focused claims. Partners refer clients there for direct assessment, and the referral tracking follows the client through to engagement close.