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Business Tax

Employee Retention Credit Audit & Controversy Services

Be prepared for anything that comes your way. Aprio has the Employee Retention Credit (ERC) eligibility knowledge and IRS experience you need to navigate ERC audits with confidence.

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Eligibility clarification. Audit notices.

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Although the Employee Retention Credit (ERC) was created to help businesses through the pandemic, the nature of the credit has led to potential abuse. Now, many taxpayers that claimed the ERC are receiving notices from the IRS.

Whether you have already received an IRS notice or are concerned that you might, Aprio is here to help. As nationally-recognized leaders in eligibility analysis, our dedicated tax controversy practice can provide comprehensive IRS audit representation to help mitigate ERC audit risk before it escalates.

Our Focus Areas

Whether you’re facing an ERC audit now or want to be prepared for what may come, Aprio will be there to help you every step of the way:

  • ERC Eligibility Review

    Our advisors will assess the strength of your ERC claim by reviewing qualification criteria, wage calculations, and supporting documentation.

  • Audit Readiness & Documentation

    We’ll help you achieve ERC audit preparedness through a thorough review of your ERC position and the creation of a detailed audit trail.

  • Professional Opinion Memos

    You’ll receive a detailed memorandum outlining Aprio’s professional opinion on your ERC eligibility and supporting compliance with IRS standards.

  • Data Compilation

    Aprio will centralize all supporting ERC documentation in a secure, easily accessible system to streamline communication and response.

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The OBBB and ERC Audit Risk: Three Steps to Defending Your Claim

  • September 9, 2025
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Your ERC Audit Specialists

Nationally-recognized leaders in ERC claims, audits, and controversy

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Frequently Asked Questions

What are the key audit risk factors for ERC claims?

High audit risk factors include:

  • Claims filed by providers that began during the pandemic and have “ERC” in their name
  • Failure to aggregate controlled-group entities when determining eligibility
  • Incorrectly claiming all quarters without specific eligibility
  • Lack of amended tax returns under IRC 280C when required

If you’ve recently received a notice of ERC audit from the IRS, contact Aprio right away.

What is the statute of limitations for ERC audits?

The IRS generally has three years from the date you file your payroll tax return to audit your Employee Retention Credit (ERC) claim. However, if a claim was understated by more than 25%, the statute of limitations can extend to six years, and claims involving fraud or intentional misrepresentation have no time limit.

What happens if an ERC claim is disallowed or found improper?

If your ERC claim is disallowed, you may have to repay the amount, pay interest and penalties, and potentially face criminal investigation if fraud or misrepresentation is involved. The statute of limitations can be extended for claims involving misrepresentation, increasing financial exposure.

Can I remediate a questionable ERC claim before an audit and avoid penalties?

Yes. The IRS offers a withdrawal option for unprocessed ERC claims—and a voluntary-disclosure program—for eligible taxpayers to withdraw or correct claims filed before certain dates. Participating may reduce or eliminate interest and penalties compared to undergoing a full audit

Be prepared for anything that comes your way.

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