Kernrechtsfrage
Whether the appeal in international tax assistance raises a fundamental legal question under Art. 84a BGG
Extrahierter Entscheid
No fundamental legal question was shown; the appeal did not meet the admissibility requirements.
Extrahierte Begründung
The appellants' characterization of the issue as the criteria for 'playing the legal person game' was only a metaphor. The decisive point was whether the structure had been used to deceive the US tax authorities, a factual assessment already made by the lower court on multiple indicia.