Complex tax advisory, cannabis and regulated industries, and representation before the IRS and California Franchise Tax Board — for business owners and the attorneys who advise them.
Multi-entity partnerships and S-corporations, asset acquisitions and reorganizations, basis reconstruction, and the timing decisions that quietly determine the tax bill.
Entity structure, §280E positioning, and compliance for operators most firms — and most banks — would rather not touch. Built on active work with cultivators and multi-entity cannabis groups.
Examinations, appeals, and penalty defense — from the first IDR response through resolution. Methodical, and hard to rattle.
Pass-through structuring, carried interest, RIC and master-feeder experience, and the arcane corners of the code where real money is won or lost.
IRS accumulated-earnings penalty asserted against a corporate taxpayer — defended and defeated.
Tax saved by converting more than $200M of ordinary income into capital gains — a problem the client's outside Big-4 advisors and attorneys had been unable to crack.
Solved independentlyNet operating loss preserved through state-tax restructuring — a shield against $3B of income in a high-tax state.
Funds and entities whose tax function he oversaw — with the financial, regulatory, and tax audits that came with them, managed year after year.
Age at which he was named Senior Vice President of a $190B+ institutional asset manager — among the youngest in the firm's history.
Representative prior matters. Outcomes depend on the specific facts and circumstances of each engagement and do not guarantee similar results.
Kossler's edge is pattern recognition — reading new tax law closely and seeing the consequences others miss: where a statute creates value the market hasn't priced yet, and where running the rules literally produces results no one expected.
He was early to the Employee Retention Credit — identifying the opportunity ahead of the wave and writing on it before it became an industry. And where others filed indiscriminately, he stayed deliberately selective, screening engagements closely at a time when no one yet knew how the IRS would respond. Spotting the opening early, and respecting the risk — that judgment is what he brings to every aggressive-but-defensible position.
Richard J. Kossler III, CPA, MBT, is the tax specialist other CPAs and attorneys call when the situation is complicated.
He built that depth over more than two decades. Big-4 trained at EY and KPMG, Richard earned a Master of Business Taxation from USC before spending eleven years at a $190 billion-plus institutional asset manager, where he rose to Senior Vice President by age 30. There he oversaw the tax function across more than 30 funds and entities, defeated a $30 million IRS penalty, and solved a $70 million tax problem the company's outside Big-4 advisors and attorneys had been unable to crack.
Today he brings that institutional-grade expertise to business owners and their counsel — people who need someone who genuinely understands the arcane corners of the tax code, not a template.
If it doesn't fit a template, it's worth a conversation.
Engagements are selective and matter-based.