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.
Tell me briefly what you need help with and any deadline. Please don’t email tax returns, account numbers, or other sensitive documents.
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.
I’m Richard Kossler, a California CPA based in Irvine. I advise business owners and their counsel on complex tax matters.
My work includes entity structuring, cannabis and regulated industries, and representation before the IRS and California Franchise Tax Board.
My background includes EY, KPMG, and eleven years at an institutional asset manager, where I led the tax function as Senior Vice President. I earned my Master of Business Taxation at USC.
If it doesn't fit a template, it's worth a conversation.
A brief description and any deadline are enough to start. Please don’t email confidential documents.
Engagements are selective and matter-based.
Direct links to official tax agency websites.