On February 20, 2026, the Supreme Court struck down an extensive series of tariffs imposed last year by President Trump, holding that they were not authorized under the International Emergency Economic Powers Act (“IEEPA”).  And on March 4, 2026, the United States Court of International Trade began the process of refunding certain of “the millions of entries that were subject to IEEPA,” through a process known in the international trade context as liquidating. 

These recent decisions by the Supreme Court and Court of International Trade may prompt federal contractors to consider seeking refunds of tariffs paid to import goods required to perform under their government contracts.  As we covered in a previous post, government contracts may contain clauses allowing for price increases following the imposition of a new federal tax.  These clauses can also work the other way and require a price decrease (or a credit to the Government under a cost-reimbursement contract) in the event of an after-relieved tax.  

Fixed-price contracts.  Many fixed-price contracts include the clause at FAR 52.229-3, which provides that the contract price shall be decreased by the amount of any “after-relieved Federal tax,” defined as “any amount of Federal excise tax or duty, except social security or other employment taxes, that would otherwise have been payable on the transactions or property covered by this contract, but which the Contractor is not required to pay or bear, or for which the Contractor obtains a refund or drawback, as the result of legislative, judicial, or administrative action taking effect after the contract date.”  (Some contracts may instead include FAR 52.229-4, which includes similar provisions.)  In the event of an after-relieved tax, such as a tariff, the contractor must “promptly notify” their contracting officer “of all matters relating to” the tariff “that reasonably may be expected to result in . . . [a] decrease in the contract price,” and to follow “appropriate action” directed by the contracting officer accordingly.  FAR 52.229-3(g).  If neither FAR 52.229-3 nor FAR 52.229-4 is incorporated in a particular contract, contractors should have a sound argument that the Government failed to protect any right to a price reduction, and that the contractor is not obligated to decrease its contract price to account for a refunded tariff.

As discussed in our previous post, we have not identified any precedent in which a court has expressly determined whether FAR 52.229-3 or FAR 52.229-4 applies to a “tariff.”  Nor has any court directly addressed whether illegally imposed duties or tariffs constitute an “after-relieved tax” subject to the clause.  However, it bears emphasis that the Executive Orders that imposed the tariffs, as well as the Supreme Court opinion, used the terms “tariff” and “duty” interchangeably.

Cost-reimbursement contracts.  Cost-reimbursement contracts are subject to several provisions that might obligate contractors to provide a credit or payment to the Government for any tariff refunds that were originally treated as allowable costs.  Most directly, FAR 31.205-41(d) provides that “[a]ny taxes, interest, or penalties that were allowed as contract costs and are refunded to the contractor shall be credited or paid to the Government in the manner it directs.”  More broadly, FAR 31.201-5 provides that “the applicable portion of any income, rebate, allowance, or other credit relating to any allowable cost and received by or accruing to the contractor shall be credited to the Government either as a cost reduction or by cash refund.” Finally, the standard Allowable Cost and Payment clause, FAR 52.216-7(h)(2), provides that a contractor must “pay to the Government any refunds, rebates, credits, or other amounts (including interest, if any) accruing to or received by the Contractor or any assignee under this contract, to the extent that those amounts are properly allocable to costs for which the Contractor has been reimbursed by the Government.” 

In other words, contractors performing under cost-reimbursement arrangements will generally be subject to a contractual obligation to make an appropriate credit or payment to the Government upon receiving refunds of tariffs that have been allocated to contracts.

Conclusion.  For government contractors, tariff refunds come with obligations.  As is often the case, navigating these obligations will require timely documentation, careful assessment of relevant facts, and financial and legal analysis.  We’d be pleased to assist with any questions as they arise. 

Photo of Peter B. Hutt II Peter B. Hutt II

Peter Hutt represents government contractors in False Claims Act and fraud matters, and accounting, cost, and pricing disputes and counseling matters.

Peter is a leading False Claims Act lawyer in the government contracts arena. He has represented contractors for 35 years in matters…

Peter Hutt represents government contractors in False Claims Act and fraud matters, and accounting, cost, and pricing disputes and counseling matters.

Peter is a leading False Claims Act lawyer in the government contracts arena. He has represented contractors for 35 years in matters alleging cybersecurity noncompliance; cost mischarging; CAS violations; quality assurance deficiencies; substandard products and services; defective pricing; health care fraud; price reduction issues; inadequate subcontractor oversight; and reverse false claims. He has testified before Congress concerning the False Claims Act, and is a thought leader in the field. Peter also conducts internal investigations and advises clients on whether and how to make disclosures of potential wrongdoing.

Peter also represents contractors and grantees in accounting, cost, and pricing matters, and other contract and grant matters. He has addressed issues concerning pensions and post-retirement benefits; TINA and defective pricing; alleged CAS violations; cost accounting practice changes; alleged charging of unallowable and expressly unallowable costs; terminations; contract financing; price reduction clause issues; subcontracting and supply chain compliance; specialty metals compliance; and small business and DBE compliance. He has litigated cost, accounting, and contract breach matters in the Court of Federal Claims and the ASBCA.

Peter is recognized for his work both in False Claims Act and government contract disputes by Chambers USA, which notes that “He is absolutely outstanding. He is thoughtful and client-focused.” Chambers also notes that “Peter’s judgment and problem solving ability is unique. He is a very good False Claims Act lawyer.”

Photo of Elizabeth Witwer Elizabeth Witwer

Elizabeth Witwer represents government contractors litigating contract claims and performance disputes against the U.S. government and other contractors, such as claims under the Contract Disputes Act (CDA), defective pricing claims, cost-allowability disputes, prime-sub disputes, and matters involving termination for convenience and breach of…

Elizabeth Witwer represents government contractors litigating contract claims and performance disputes against the U.S. government and other contractors, such as claims under the Contract Disputes Act (CDA), defective pricing claims, cost-allowability disputes, prime-sub disputes, and matters involving termination for convenience and breach of contract. She litigates cases in a variety of venues, including the Boards of Contract Appeals and the U.S. Court of Federal Claims (COFC).

Elizabeth joined the firm after serving as an Administrative Judge on the Armed Services Board of Contract Appeals (ASBCA), where she was responsible for adjudicating disputes arising under the CDA between contractors and federal agencies, including the Department of Defense, NASA, and the CIA.

Prior to serving at the ASBCA, Elizabeth held overlapping positions at the U.S. Government Accountability Office (GAO) as a Senior Attorney in the Procurement Law Division and as a member of GAO’s Contract Appeals Board. In these roles, she dual-hatted as adjudicator of bid protests challenging federal procurements and presided over contract disputes between contractors and legislative branch agencies.

Earlier in her career, Elizabeth served as a Trial Attorney in the Civil Division of the Department of Justice, where she defended the United States and federal agencies in contract, employment, and constitutional disputes before the U.S. Court of Appeals for the Federal Circuit and the COFC. She also served on active duty in the U.S. Army as counsel to the Army’s Legal Services Agency and the 4th Infantry Division on procurement matters and contract litigation, including while deployed to Iraq.

In addition to her legal practice, Elizabeth is a Colonel in the U.S. Army Reserve. 

Photo of Peter Terenzio Peter Terenzio

Peter Terenzio advises clients regarding the regulatory requirements that govern federal contractors and grantees. He focuses on helping clients navigate the Cost Accounting Standards (CAS) and the cost principles in FAR Part 31 and 2 CFR Part 200. He also routinely advises on…

Peter Terenzio advises clients regarding the regulatory requirements that govern federal contractors and grantees. He focuses on helping clients navigate the Cost Accounting Standards (CAS) and the cost principles in FAR Part 31 and 2 CFR Part 200. He also routinely advises on Other Transaction Authority (OTA) research, prototype, and production agreements.

Peter works on accounting, cost, and pricing matters, including providing day-to-day compliance advice; assisting with responses to audits and investigations and findings of potential noncompliance; and performing internal investigations of alleged violations. He also advises on other regulatory regimes, including the complicated prevailing wage rules imposed by the Davis Bacon Act (DBA) and Service Contact Act (SCA). He has particular experience with prototype OTAs issued in cutting edge fields, including quantum computing and biotechnology.

Peter also represents contractors in disputes arising under contracts and grants. He knows how to work closely with the client’s subject matter experts to prepare and submit detailed requests for equitable adjustment (REAs) to secure price or schedule relief. When contract disputes cannot be resolved amicably, he has helped clients in litigation before federal courts and the Boards of Contract Appeals.

Photo of Robert Huffman Robert Huffman

Bob Huffman counsels government contractors on emerging technology issues, including artificial intelligence (AI), cybersecurity, and software supply chain security, that are currently affecting federal and state procurement. His areas of expertise include the Department of Defense (DOD) and other agency acquisition regulations governing…

Bob Huffman counsels government contractors on emerging technology issues, including artificial intelligence (AI), cybersecurity, and software supply chain security, that are currently affecting federal and state procurement. His areas of expertise include the Department of Defense (DOD) and other agency acquisition regulations governing information security and the reporting of cyber incidents, the Cybersecurity Maturity Model Certification (CMMC) program, the requirements for secure software development self-attestations and bills of materials (SBOMs) emanating from the May 2021 Executive Order on Cybersecurity, and the various requirements for responsible AI procurement, safety, and testing currently being implemented under President Trump’s AI Executive Order. 

Bob also represents contractors in False Claims Act (FCA) litigation and investigations involving cybersecurity and other technology compliance issues, as well more traditional government contracting costs, quality, and regulatory compliance issues. These investigations include significant parallel civil/criminal proceedings growing out of the Department of Justice’s Cyber Fraud Initiative. They also include investigations resulting from False Claims Act qui tam lawsuits and other enforcement proceedings. Bob has represented clients in over a dozen FCA qui tam suits.

Bob also regularly counsels clients on government contracting supply chain compliance issues, including those arising under the Buy American Act/Trade Agreements Act and Section 889 of the FY2019 National Defense Authorization Act. In addition, Bob advises government contractors on rules relating to IP, including government patent rights, technical data rights, rights in computer software, and the rules applicable to IP in the acquisition of commercial products, services, and software. He focuses this aspect of his practice on the overlap of these traditional government contracts IP rules with the IP issues associated with the acquisition of AI services and the data needed to train the large learning models on which those services are based. 

Bob is ranked by Chambers USA for his work in government contracts and he writes extensively in the areas of procurement-related AI, cybersecurity, software security, and supply chain regulation. He also teaches a course at Georgetown Law School that focuses on the technology, supply chain, and national security issues associated with energy and climate change.

Photo of Victoria Skiera Victoria Skiera

Victoria Skiera is an associate in the firm’s Government Contracts Practice Group, advising contractors on a range of regulatory and compliance issues. She has experience assisting clients with unique issues arising in government contracts transactions and related due diligence processes, as well as…

Victoria Skiera is an associate in the firm’s Government Contracts Practice Group, advising contractors on a range of regulatory and compliance issues. She has experience assisting clients with unique issues arising in government contracts transactions and related due diligence processes, as well as in compliance counseling, investigations, and disputes. Victoria also has experience assessing the impact of executive order and litigation activity in the context of federal procurement and financial assistance. Victoria maintains an active pro bono practice.