Billionaire Five Hour Energy entrepreneur Manoj Bhargava maintained allegedly undeclared bank accounts worth hundreds of millions of dollars at the Swiss bank Pictet, a Senate committee chairman wrote in a letter to the bank's managing partner.
Wyden wrote that he had received documents from a whistleblower who had information about an alleged scheme to avoid U.S. taxes on a personal fortune largely built on the sale of the tiny bottles of highly caffeinated liquid at retail points of sale across the country. The whistleblower was not identified.
Wyden laid out allegations that "the documents explicitly suggest" Person 1 transferred the funds to a Bahamas entity nominally owned by another person, identified as "Person 2." Yet despite the transfer, the funds allegedly remained under Bhargava's control.An attorney for Bhargava, Bryan C. Skarlatos, told CNBC he had no comment on the letter.
The Wyden letter cited several indicators that Bhargava allegedly controlled the funds that were in the nominal possession of Person 2. Americans are permitted to maintain foreign bank accounts, but they must file so-called FBAR forms with the IRS disclosing the assets, and must pay appropriate related taxes. Bhargava was born in India, but he is a U.S. citizen who conducts business in the suburbs of Detroit.
Wyden wrote that the allegations against Bhargava and Person 2, if true, "could involve potentially the largest individual FBAR penalty in US history." The highest penalty paid to the IRS to date is $100 million.