Question juridique clé
Whether the Federal Court had jurisdiction over the appeal against the Federal Administrative Court's interim rulings in an international tax assistance matter.
Solution extraite
The Federal Court lacked jurisdiction because the matter is excluded from appeal in public law matters under the applicable exclusion rule.
Motifs extraits
The challenged rulings are procedural interim decisions in a tax assistance case based on the Swiss-U.S. treaty framework; neither the substantive tax-assistance matter nor the related interim rulings fall within federal court review jurisdiction.