Top ERC Audit Defense And Compliance Firms In 2027

Facing an IRS review of your Employee Retention Credit? Compare 10 CPA and law firms for ERC audit defense, disallowance appeals and compliance in 2027.

The Employee Retention Credit (ERC) is no longer a refund opportunity. It is a compliance issue. Many businesses claimed the pandemic-era payroll credit with help from aggressive promoters, and the IRS has spent the last several years reviewing, auditing and disallowing those claims. If you have received an IRS letter, have an unpaid claim still pending, or are worried about a claim a promoter filed for you, you need qualified help, not another sales pitch.

Here is where the law stands, in brief. The One Big Beautiful Bill Act, signed July 4, 2025, bars credits or refunds for third- and fourth-quarter 2021 ERC claims filed after January 31, 2024, and extends the IRS’s time to assess those quarters to six years. It also added a $1,000 penalty for each due diligence failure by certain ERC promoters. The IRS’s two Voluntary Disclosure Programs closed in 2024, the second on November 22, 2024. The claim withdrawal process has remained available for claims that have not been paid. After a disallowance letter (Letter 105C or 106C), a business generally has two years to resolve the claim or file a refund suit, and since April 2026 some taxpayers can use Form 907 to extend that period. Confirm current deadlines with your CPA or tax attorney, because they depend on your facts.

How we chose: every firm on this list is a CPA firm or a law firm with a named tax controversy practice. We excluded any firm whose marketing still offers new ERC refunds, “free money” or contingency-fee claims, and we did not include standalone ERC filing companies. Entries are ordered by how directly each firm describes ERC audit and controversy work, not by any promise of outcome. For broader tax planning, see our list of tax strategy firms.

ERC Audit Defense Firms At A Glance

Company	Headquarters	Best For	Standout
Aprio	National CPA and advisory firm	Businesses needing claim review and audit files	Dedicated ERC audit and controversy service
Holland & Knight	U.S. law firm, many offices	ERC audits and appeals with litigation risk	About 40 tax controversy attorneys
Chamberlain Hrdlicka	Atlanta, Houston, Philadelphia, San Antonio	Refund suits and pending-claim strategy	ERC practice with former IRS leadership
Hochman Salkin Toscher Perez	Beverly Hills, California	Businesses facing possible penalties or criminal exposure	Tax controversy and criminal tax defense boutique
Freeman Law	Texas, with offices in Dallas, Frisco and Austin	Claims needing forensic reconstruction	Tax litigators plus forensic accounting team
EisnerAmper	National CPA firm, 4,500+ professionals	Mid-sized companies wanting a CPA firm	National tax controversy practice group
Withum	National CPA firm, 30 offices	Audits of claims prepared by another firm	Represents ERC audits regardless of who filed
Kostelanetz	New York, Washington, D.C., Atlanta, Hackensack	Voluntary disclosure and fraud exposure	About 80 years in tax controversy
Caplin & Drysdale	Washington, D.C. and New York	Complex disputes and refund litigation	Tax law firm since 1964
Plante Moran	National CPA firm, 36 offices	Existing clients wanting CPA-led representation	4,500+ staff, tax controversy services

Best ERC Audit Defense And Compliance Firms In 2027

1. Aprio — Dedicated ERC Audit And Controversy Service

Aprio is a national accounting and advisory firm whose CPA entity, Aprio, LLP, is a licensed CPA firm. It runs a specific Employee Retention Credit audit and controversy service for businesses that have received IRS notices or expect them. The service covers four areas: an eligibility review of qualification criteria, wage calculations and supporting documents; audit readiness and documentation; professional opinion memos on eligibility; and secure compilation of ERC records for IRS responses.

Aprio says its ERC controversy team has more than 20 years of experience dealing with the IRS, and it pairs that work with IRS audit representation from its wider tax controversy practice. It also explains the withdrawal and disclosure options for existing claims. Its current ERC page does not offer to file new claims or quote contingency fees.

Aprio is a sensible first call for a business that is not sure whether its claim would survive an exam and wants a structured review before the IRS asks.

Best for: Businesses that want an independent review of an existing claim and an audit-ready file.

2. Holland & Knight — Law Firm Tax Controversy Team Handling ERC Audits And Appeals

Holland & Knight is a large U.S. law firm whose tax controversy and litigation practice handles IRS audits, appeals, Tax Court and federal court litigation, state and local disputes, and criminal tax defense. The firm lists employee retention credit audits and appeals among its IRS audit defense work.

The practice has about 40 attorneys, some of whom previously held leadership roles at the IRS, the Department of Justice and the Treasury Department. That experience is valuable when an ERC exam involves contested legal questions, such as whether a government order caused a partial suspension of operations.

Working with a law firm also keeps communications privileged, which matters if a claim may involve penalties or promoter issues.

Best for: Businesses with larger claims where an audit could become an appeal or lawsuit.

3. Chamberlain Hrdlicka — ERC Practice With Former IRS Leadership

Chamberlain Hrdlicka is a multidisciplinary law firm with offices in Atlanta, Houston, Philadelphia and San Antonio, and it lists Employee Retention Tax Credit work as a practice area. Atlanta tax attorney Tom Cullinan, a former IRS Counselor to the Commissioner and acting Chief of Staff, has written in Forbes about options for businesses with ERC refund claims stuck at the IRS, including the Taxpayer Advocate Service and refund suits.

Cullinan has written that the firm will consider alternative fee arrangements for businesses with smaller claims that want to file refund suits, while stressing that litigation requires a well-documented claim.

The firm is a good fit for businesses whose claims are pending or disallowed and who want to know whether a refund suit is realistic.

Best for: Businesses weighing a refund suit over a pending or disallowed claim.

4. Hochman Salkin Toscher Perez — Tax Controversy And Criminal Tax Defense Boutique

Hochman Salkin Toscher Perez P.C. is a Beverly Hills tax law firm that handles tax audits and administrative appeals, civil tax litigation, criminal tax defense, collection matters and federal and state employment tax audits and investigations. It serves clients across the United States.

The firm’s attorneys have written and spoken extensively on ERC enforcement, including articles on the IRS ERC Voluntary Disclosure Program, the IRS’s civil and criminal enforcement push, the ERC enforcement measures in the One Big Beautiful Bill Act, and professional responsibility warnings for practitioners reviewing ERC positions.

This is the kind of firm to call when an ERC claim raises questions beyond eligibility, such as possible penalties, inaccurate records prepared by a promoter, or contact from IRS Criminal Investigation.

Best for: Businesses facing penalty exposure or concerns about how a promoter prepared their claim.

5. Freeman Law — Tax Litigators With Forensic Accounting Support

Freeman Law is a Texas-based law firm with offices in Dallas, Frisco, Austin, Washington, D.C. and Mexico City. Its tax litigation practice covers Tax Court litigation, IRS penalty defense, collections defense and criminal tax defense, and it has forensic accounting and investigations professionals on staff.

In an October 2026 article on ERC audits, managing member Jason B. Freeman explains the six-year assessment period for late-2021 quarters, the payment bar on claims filed after January 31, 2024, the two-year window after a disallowance letter, and recent court decisions on the “due to” government order test. He notes that defending a claim often starts with reconstructing how it was calculated.

That forensic angle helps businesses whose claim was prepared by an outside ERC company that left little documentation behind.

Best for: Businesses that need their claim rebuilt and documented before defending it.

6. EisnerAmper — National CPA Firm With A Tax Controversy Practice Group

EisnerAmper is one of the largest accounting, tax and business advisory firms in the U.S., with more than 4,500 professionals. Its Tax Controversy and Dispute Resolution practice is led nationally by Miri Forster, who has more than 25 years of experience in tax dispute resolution for corporations, partnerships and high-net-worth individuals.

EisnerAmper published guidance on the ERC Voluntary Disclosure Program when it opened and reopened, and it maintains an ERC topic hub. Its advice has consistently urged businesses to review eligibility with a trusted advisor rather than rely on promoters.

EisnerAmper suits mid-sized and larger companies that want ERC review and IRS representation from the same firm that handles their regular tax work.

Best for: Mid-sized companies that want a national CPA firm managing the IRS relationship.

7. Withum — CPA Firm That Represents ERC Audits Regardless Of Who Filed

Withum is a national advisory and public accounting firm with about 3,200 team members and 30 offices. Its tax controversy group represents business and individual taxpayers in audits, Fast Track Settlement, formal appeals and penalty abatement requests, and lists employment taxes among its areas of expertise.

Withum began writing about IRS ERC audits early, explaining that exams focus on eligibility, the calculation and whether income tax returns were amended to reduce wage deductions. The firm has said it is available to assist any business selected for an ERC audit, even if the credit was calculated by another firm.

That makes Withum a practical option for a business whose original ERC company is unresponsive or gone.

Best for: Businesses whose claim was prepared by a third party that can no longer support it.

8. Kostelanetz — Long-Established Tax Controversy And Voluntary Disclosure Firm

Kostelanetz LLP is a tax controversy and white-collar defense law firm with about 80 years of history and offices in New York, Washington, D.C., Atlanta and Hackensack. Its practice areas include civil tax controversies and litigation, criminal tax investigations, voluntary disclosures and internal investigations.

Its civil practice represents companies and individuals in IRS audits, assessments and appeals, and in litigation in the Tax Court, district courts and the Court of Federal Claims. It also handles payroll tax matters at the New York State and City level.

The firm does not market an ERC-specific service, but its voluntary disclosure and fraud defense experience is relevant for businesses that discover their claim may have been improper and need to decide how to correct it.

Best for: Businesses that may need to correct an improper claim and want experienced defense counsel.

9. Caplin & Drysdale — Tax Law Firm Practicing Since 1964

Caplin & Drysdale is a tax-focused law firm founded in 1964, with offices in Washington, D.C. and New York. Its practices include tax disputes and litigation, criminal tax and white-collar defense, and business and transactional tax.

The firm does not list an ERC-specific offering, but its tax disputes group handles the kinds of matters ERC claims are turning into: examinations, appeals, refund suits and penalty disputes. It is also a good fit when ERC exposure shows up in due diligence on an acquisition.

Caplin & Drysdale is best for complex or high-dollar disputes where specialized tax litigation experience matters more than volume.

Best for: High-dollar ERC disputes and deals where ERC exposure is a diligence issue.

10. Plante Moran — Large CPA Firm With Tax Controversy Services

Plante Moran is one of the largest certified public accounting and business advisory firms in the U.S., with more than 100 years in operation, more than 4,500 staff and 36 offices. It lists tax controversy services as part of its tax practice.

The firm does not market a separate ERC product. For businesses that already use Plante Moran, or that want a large CPA firm with deep regional roots, its controversy team can handle IRS correspondence, exams and appeals tied to an ERC claim alongside the related income tax adjustments.

Keeping the ERC response with the firm that prepares your income tax returns helps make sure the wage deduction adjustments line up with any disallowance.

Best for: Businesses that want CPA-led ERC representation tied to their regular returns.

How To Choose An ERC Audit Defense Firm

Is The Firm Credentialed?

Only attorneys, CPAs and enrolled agents can represent you before the IRS without limits. Ask for the names and credentials of the people who will handle your file, and check them with your state board of accountancy or bar.

Is The Firm Still Selling New ERC Refunds?

Walk away from any of the many ERC companies still promising new refunds, “free money” or fees based on the size of your credit. The filing window has effectively closed and the IRS has warned repeatedly about these pitches. A good defense firm will start by reviewing whether your existing claim was valid.

What Is Your Deadline?

If you received a Letter 105C or 106C, the two-year period to sue for a refund generally runs from the date of the letter, and filing an appeal does not stop it. Bring the letter to your first meeting so the firm can calendar the deadline.

Do You Need A Lawyer Or A CPA?

A CPA firm is often the right fit for eligibility reviews and routine exams. A law firm is better when penalties, fraud concerns, promoter problems or litigation are possible, because legal privilege can protect your communications.

How Will Fees Work?

Ask for an hourly estimate or a defined scope for each phase: review, exam response, appeal and litigation. Be cautious of contingency fees tied to refund amounts.

Frequently Asked Questions

Can I Still File A New ERC Claim?

The general deadlines to file ERC claims have passed, and the 2025 law bars payment on late-2021 claims filed after January 31, 2024. Talk to a CPA or tax attorney before relying on any claim, new or old.

What Is The ERC Claim Withdrawal Process?

Businesses with unpaid claims have been able to ask the IRS to withdraw them, which treats the claim as never filed. Ask your advisor whether it is still available for your claim.

What Should I Do After An ERC Disallowance?

Read the letter carefully, note the date, and get qualified help quickly. Options can include responding with documentation, an appeal and, within the deadline, a refund suit.

What If A Promoter Filed My Claim?

You are still responsible for the claim. Gather everything the promoter gave you and have an independent CPA or tax attorney review it.

Conclusion

ERC work in 2027 is about defense and cleanup. Aprio, EisnerAmper, Withum and Plante Moran give you CPA-led review and representation, while Holland & Knight, Chamberlain Hrdlicka, Hochman Salkin Toscher Perez, Freeman Law, Kostelanetz and Caplin & Drysdale bring tax controversy lawyers for appeals, penalty issues and litigation. Choose a credentialed firm, avoid anyone still selling refunds, and act before your deadlines run. For ongoing tax help, see our list of real estate CPA firms for investors.

This article is general information, not tax or legal advice.