Question juridique clé
Whether the appeal against the Federal Administrative Court's ruling in international assistance to the USA was admissible before the Federal Supreme Court.
Solution extraite
The appeal was not admissible because the case concerned administrative, not criminal, assistance.
Motifs extraits
Requests by the IRS under the treaty and later agreements are handled through administrative assistance. Article 83(h) LTF excludes such cases from ordinary public-law appeals, and Article 84 LTF applies only to international criminal assistance.