Beginning in 2004, Apple Inc. began to use a network of tax treaties signed by Ireland to avoid paying tax on its non-US income. Known as the Double Irish, the tax loophole allowed companies, primarily US multinationals like Apple, to sell and loan intellectual property rights from wholly-owned subsidiaries in different national jurisdictions in order to avoid paying taxes on those assets. Use of the Double Irish, long considered legal, led to the EU fining Apple Inc. 13 billion euros in unpaid taxes and forcing Ireland to change some of its tax laws. Apple Inc. plans on appealing the tax fine by the EU. In order to do so, Apple Inc. must put the full amount of the fine in "escrow", or a third party account, that will pay out the fine if the appeal fails and return the money to Apple Inc. if it wins. In order to raise the 13 billion euros, Apple Inc. issues a "Fine Bill" for anyone who wants to pay into the fine escrow to be paid back their money plus any increases in the value of the cash due to inflation. The money will only be paid back if Apple Inc. wins its appeal. Ireland is a part of the EU on the basis of a series of treaties it has signed with other EU nations. Ireland and the US have a bilateral investment treaty like all others (including equal treatment and compensation for any asset seizures). Question: Is the "Fine Bill" issued by Apple Inc. a "security" that should be regulated under either the '33 and/or '34 Acts? Explain