Richard J. Kossler III  ·  CPA  ·  MBT

M&A. Partnerships.
Tax controversy.

M&A and business exit tax planning, complex partnership and owner tax planning, and IRS/FTB controversy representation — for business owners, founders, and their counsel.

Discuss your matter

Use the short inquiry form to describe your matter and any deadline. Please keep confidential documents out of the form.

USC — Master of Business Taxation · Former SVP, Tax — The TCW Group · KPMG · EY · CPA, California
§Practice

M&A & Business Exit Tax Planning

Tax planning for business acquisitions, sales, divestitures, and restructurings. I evaluate how the deal structure affects the tax result for the business and its owners, then coordinate the tax work with transaction counsel and the other advisers.

  • Asset and equity sale alternatives and owner net proceeds
  • Acquisition and disposition structuring and purchase-price allocations
  • Transaction tax reporting and post-closing implementation

Complex Partnership & Owner Tax Planning

Partnerships, LLCs, and ownership structures where the entity and its owners can have different tax consequences. I work through ownership changes, partner buyouts, and basis and capital account issues, connecting the agreements and financial records to the tax analysis.

  • Partner admissions, redemptions, buyouts, and transfers of interests
  • Partner basis, capital accounts, and debt allocation issues
  • Multi-entity reporting, S corporation issues, and owner-level planning

IRS & California FTB Controversy

Representation in IRS and California Franchise Tax Board business examinations, with technical tax support for owners and their counsel. I organize the records, reconcile tax returns to the financial information, and develop written responses and support for tax positions.

  • Business examinations and information document requests
  • Cannabis tax disputes under §280E and cost of goods sold support
  • Penalty relief and coordination with tax counsel

Ongoing Tax Advisory & Implementation

Continuing tax oversight for owners with multiple entities, investments, and transactions. Planning is carried through to the returns and supporting records, with direct senior involvement and coordination with counsel.

  • Consolidated corporate and related-entity tax reporting
  • Owner and entity planning, including qualified small business stock
  • California residency and multi-state tax considerations
§Relevant Experience
M&A

Acquisitions, divestitures, entity restructurings, and asset and equity transactions, with analysis of the tax consequences for the business and its owners.

Funds

Partnership, private equity, and investment fund tax experience, including multi-entity structures, ownership changes, and coordination between entity and owner tax reporting.

11years

At The TCW Group, including eight years as Senior Vice President of Tax, with responsibilities spanning corporate and investment fund tax operations.

IRS

Business examinations and tax controversy work involving the IRS and California Franchise Tax Board, including cannabis tax matters under §280E.

Big 4

Tax roles at EY and KPMG, followed by corporate tax leadership and independent practice. Master of Business Taxation from the University of Southern California.

Experience is described at the practice level without identifying confidential client matters. Services depend on the facts and circumstances of each engagement.

§Approach

Understand the structure.
Support the position.

My work starts with the underlying transaction, ownership structure, and financial records. I examine how the relevant tax rules apply and where the facts, agreements, and reporting need to be reconciled.

I combine technical research with practical implementation and work directly with owners and counsel. The aim is supported analysis and clear decisions before a return is filed, a transaction closes, or an examination response goes out.

§Meet Richard
Richard J. Kossler III, CPA, MBT

I’m Richard Kossler, founding partner of Steward Hamilton CPA Inc. in Irvine, California. I advise business owners and their counsel on transactions, complex ownership structures, and tax controversies.

My practice focuses on M&A and business exit tax planning, complex partnership tax, and representation before the IRS and California Franchise Tax Board, including cannabis tax matters under §280E.

My background includes EY, KPMG, and eleven years at The TCW Group, the last eight as Senior Vice President of Tax. I earned my Master of Business Taxation at USC.

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§Contact

If it doesn't fit a template, it's worth a conversation.

Discuss your matter

A brief description and any deadline are enough to start. Please keep confidential documents out of the form.

Email rk@shco.cpa
Telephone 949.216.7878
Office Irvine, California

Engagements are selective and matter-based.

§New inquiries

Discuss your matter.

Tell me what you need help with and any deadline. A short overview is enough to start. I’ll review your inquiry and follow up.

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Client resources

Direct links to official tax agency websites.