Notes to Consolidated Financial Statements Ball Corporation and Subsidiaries 14.
Taxes on Income (continued) At December 31, 2007, Ball Corporation and its domestic subsidiaries had net operating loss carryforwards, expiring between 2020 and 2026, of $64.6 million with a related tax benefit of $25.2 million.
Also at December 31, 2007, Ball Packaging Europe and its subsidiaries had net operating loss carryforwards, with no expiration date, of $54.4 million with a related tax benefit of $14.6 million.
Ball Packaging Products Canada Corp.  had a net operating loss carryforward, with no expiration date, of $15.8 million with a related tax benefit of $5.4 million.
Due to the uncertainty of ultimate realization, these European and Canadian benefits have been offset by valuation allowances of $8.6 million and $5.4 million, respectively.
Upon realization, $5.3 million of the European valuation allowance will be recognized as a reduction in goodwill.
At December 31, 2007, the company has foreign tax credit carryforwards of $5.8 million; however, due to the uncertainty of realization of the entire credit, a valuation allowance of $3.8 million has been applied to reduce the carrying value to $2 million.
Effective January 1, 2007, Ball adopted FIN No.48, “Accounting for Uncertainty in Income Taxes.
” As of the date of adoption, the accrual for uncertain tax position was $45.8 million, and the cumulative effect of the adoption was an increase in the reserve for uncertain tax positions of $2.1 million.
The accrual includes an $11.4 million reduction in opening retained earnings and a $9.3 million reduction in goodwill.
A reconciliation of the unrecognized tax benefits follows:
## Table 0 ##
The amount of unrecognized tax benefits at December 31, 2007, that, if recognized, would reduce tax expense is $35.9 million.
At this time there are no positions where the unrecognized tax benefit is expected to increase or decrease significantly within the next 12 months.
U. S.  Federal and state income tax returns filed for the years 2000- 2006 are open for audit, with an effective settlement of the Federal returns through 2004.
The income tax returns filed in Europe for the years 2002 through 2006 are also open for audit.
The company’s significant filings in Europe are in Germany, France, the Netherlands, Poland, Serbia and the United Kingdom.
The company recognizes the accrual of interest and penalties related to unrecognized tax benefits in income tax expense.
During the year ended December 31, 2007, Ball recognized approximately $2.7 million of interest expense.
The accrual for uncertain tax positions at December 31, 2007, includes approximately $5.1 million representing potential interest expense.
No penalties have been accrued.
The 2007 provision for income taxes included an $11.5 million accrual under FIN No.48.
The majority of this provision was related to the effective settlement during the third quarter of 2007 with the Internal Revenue Service for interest deductions on incurred loans from a company-owned life insurance plan.
The total accrual at December 31, 2007, for the effective settlement of the applicable prior years 2000-2004 under examination, and unaudited years 2005 through 2007, was $18.4 million, including estimated interest.
The settlement resulted in a majority of the interest deductions being sustained with prospective application that results in no significant impact to future earnings per share or cash flows.
ITEM 7 Management’s Discussion and Analysis of Financial Condition and Results of Operations ?
Reducing annual capital expenditures to approximately $100 million in 2019; ?
Lowering General and administrative expenses (“G&A”) to 1.7% of system sales in 2019; and ?
Maintaining an optimized capital structure of ~5.0x Earnings Before Interest, Taxes, Depreciation and Amortization (“EBITDA”) leverage.
From 2017 through 2019, we intend to return an additional $6.5— $7.0 billion to shareholders through share repurchases and cash dividends.
We intend to fund these shareholder returns through a combination of refranchising proceeds, free cash flow generation and maintenance of our five times EBITDA leverage.
We anticipate generating proceeds in excess of $2 billion, net of tax, through our refranchising initiatives.
Refer to the Liquidity and Capital Resources section of this MD&A for additional details.
Beginning in 2017, we changed our fiscal year from a year ending on the last Saturday of December to a year beginning on January 1 and ending on December 31 of each year.
Concurrently, we removed the reporting lags from the fiscal calendars of our international subsidiaries.
Our MD&A has been recast to reflect the change in our reporting calendar.
See Notes 2 and 5 for additional details related to our fiscal calendar.
We intend for this MD&A to provide the reader with information that will assist in understanding our results of operations, including performance metrics that management uses to assess the Company’s performance.
Throughout this MD&A, we commonly discuss the following performance metrics: ?
Same-store sales growth is the estimated percentage change in sales of all restaurants that have been open and in the YUM system for one year or more.  ?
Net new units represents new unit openings, offset by store closures.  ?
Company restaurant profit (“Restaurant profit”) is defined as Company sales less expenses incurred directly by our Companyowned restaurants in generating Company sales.
Company restaurant margin as a percentage of sales is defined as Restaurant profit divided by Company sales.
Within the Company sales and Restaurant profit sections of this MD&A, Store Portfolio Actions represent the net impact of new unit openings, acquisitions, refranchising and store closures, and Other primarily represents the impact of same-store sales as well as the impact of changes in costs such as inflation/deflation.  ?
Operating margin is Operating Profit divided by Total revenues.
In addition to the results provided in accordance with Generally Accepted Accounting Principles in the United States of America (“GAAP”), the Company provides the following non-GAAP measurements.  ?
System sales, System sales excluding the impacts of foreign currency translation (“FX”), and System sales excluding FX and the impact of the 53rd week in 2016.
System sales include the results of all restaurants regardless of ownership, including Companyowned and franchise restaurants that operate our Concepts.
Sales of franchise restaurants typically generate ongoing franchise and license fees for the Company at a rate of 3% to 6% of sales.
Franchise restaurant sales are not included in Company sales on the Consolidated Statements of Income; however, the franchise and license fees are included in the Company’s revenues.
We believe System sales growth is useful to investors as a significant indicator of the overall strength of our business as it incorporates all of our revenue drivers, Company and franchise same-store sales as well as net unit growth.  ?
Diluted Earnings Per Share from Continuing Operations excluding Special Items (as defined below); ?
Effective Tax Rate excluding Special Items; ?
Core Operating Profit and Core Operating Profit excluding the impact of the 53rd week in 2016.
Core Operating Profit excludes Special Items and FX and we use Core Operating Profit for the purposes of evaluating performance internally.
These non-GAAP measurements are not intended to replace the presentation of our financial results in accordance with GAAP.
Rather, the Company believes that the presentation of these non-GAAP measurements provide additional information to investors to facilitate the comparison of past and present operations, excluding items that the Company does not believe are indicative of our ongoing operations due to their size and/or nature.
Special Items are not included in any of our Division segment results as our chief operating decision maker does not consider the impact of these items when assessing segment performance.
Certain non-GAAP measurements are presented excluding the impact of FX.
These amounts are derived by translating current year results at prior year average exchange rates.
We believe the elimination of the FX impact provides better year-to-year comparability without the distortion of foreign currency fluctuations.
We provide Core Operating Profit excluding 53rd week and System sales excluding 53rd week to further enhance the comparability with the lapping of the 53rd week that was part of our fiscal calendar in 2016.
Summary All comparisons within this summary are versus the same period a year ago and include the impact of lapping a 53rd week in 2016, unless otherwise noted.
For 2017, GAAP diluted EPS from continuing operations increased 48% to $3.77 per share, and diluted EPS from continuing operations excluding Special Items, increased 20% to $2.96 per share.2017 financial highlights:
## Table 1 ##
PART II ITEM 7 Management’s Discussion and Analysis of Financial Condition and Results of Operations
## Table 2 ##
In 2017, the decreases in Company sales and Restaurant profit associated with store portfolio actions were driven by refranchising, partially offset by net unit growth.
Significant other factors impacting Company sales and/or Restaurant profit were company same-store sales growth of 3%, partially offset by higher labor costs, commodity cost inflation, and increased cost of sales associated with value offerings.
In 2016, the decrease in Company sales and Restaurant profit associated with store portfolio actions was driven by refranchising, partially offset by net new unit growth.
Significant other factors impacting Company sales and/or Restaurant profit were company same-store sales growth of 1% and favorable commodity costs, partially offset by higher labor costs and store-level investments.
Franchise and License Fees and Income In 2017, the increase in Franchise and license fees and income, excluding the impact of lapping the 53rd week in 2016, was driven by refranchising, franchise same-store sales growth of 4%, and net new unit growth.
In 2016, the increase in Franchise and license fees and income, excluding the impact of the 53rd week, was driven by net new unit growth, franchise same-store sales growth of 2% and refranchising.
G&A In 2017, the decrease in G&A, excluding the impact of lapping the 53rd week in 2016, was driven by the positive impact of YUM’s Strategic Transformation Initiatives, including reductions in G&A directly attributable to refranchising, and lower litigation costs.
In 2016, the decrease in G&A, excluding the impact of the 53rd week, was driven by lapping the Live Más Scholarship contribution and lower litigation costs.
Operating Profit In 2017, the increase in Operating Profit, excluding the impact of lapping the 53rd week in 2016, was driven by same-store sales growth, lower G&A and net new unit growth, partially offset by refranchising and higher restaurant operating costs.
In 2016, the increase in Operating Profit, excluding the impact of the 53rd week, was driven by same-store sales growth, net new unit growth and lower G&A, partially offset by higher restaurant operating costs and refranchising.
Corporate & Unallocated
## Table 3 ##
NOTE 13 Derivative Instruments We use derivative instruments to manage certain of our market risks related to fluctuations in interest rates and foreign currency exchange rates.
Interest Rate Swaps We have entered into interest rate swaps with the objective of reducing our exposure to interest rate risk for our variable-rate debt interest payments related to $1.55 billion of our Term Loan B Facility, resulting in a fixed rate of 3.92% on the swapped portion of the Term Loan B Facility.
These interest rate swaps will expire in July 2021 and the notional amount, maturity date and variable rate of these swaps match those of the related debt.
These interest rate swaps are designated cash flow hedges as the changes in the future cash flows of the swaps are expected to offset changes in interest payments on the related variable-rate debt.
There were no other interest rate swaps outstanding as of December 31, 2017.
The effective portion of gains or losses on the interest rate swaps is reported as a component of AOCI and reclassified into Interest expense, net in our Consolidated Statement of Income in the same period or periods during which the related hedged interest payments affect earnings.
Gains or losses on the swaps representing hedge ineffectiveness are recognized in current earnings.
As of December 31, 2017, the swaps were highly effective cash flow hedges and no ineffectiveness has been recorded.
Foreign Currency Contracts We have entered into foreign currency forward and swap contracts with the objective of reducing our exposure to earnings volatility arising from foreign currency fluctuations associated with certain foreign currency denominated intercompany receivables and payables.
The notional amount, maturity date, and currency of these contracts match those of the underlying intercompany receivables or payables.
Our foreign currency contracts are designated cash flow hedges as the future cash flows of the contracts are expected to offset changes in intercompany receivables and payables due to foreign currency exchange rate fluctuations.
The effective portion of gains or losses on the foreign currency contracts is reported as a component of AOCI.
Amounts are reclassified from AOCI each quarter to offset foreign currency transaction gains or losses recorded within Other (income) expense when the related intercompany receivables and payables affect earnings due to their functional currency remeasurements.
Gains or losses on the foreign currency contracts representing hedge ineffectiveness are recognized in current earnings.
As of December 31, 2017, all foreign currency contracts outstanding have been highly effective cash flow hedges and no ineffectiveness has been recorded.
As of December 31, 2017 and December 31, 2016, foreign currency forward and swap contracts outstanding had total notional amounts of $456 million and $437 million, respectively.
As of December 31, 2017, we have foreign currency forward and swap contracts with durations expiring as early as February 2018 and as late as 2020.
As a result of the use of derivative instruments, the Company is exposed to risk that the counterparties will fail to meet their contractual obligations.
To mitigate the counterparty credit risk, we only enter into contracts with carefully selected major financial institutions based upon their credit ratings and other factors, and continually assess the creditworthiness of counterparties.
At December 31, 2017, all of the counterparties to our interest rate swaps and foreign currency contracts had investment grade ratings according to the three major ratings agencies.
To date, all counterparties have performed in accordance with their contractual obligations.
Gains and losses on derivative instruments designated as cash flow hedges recognized in AOCI and reclassifications from AOCI into Net Income:
## Table 4 ##
As of December 31, 2017, the estimated net gain included in AOCI related to our cash flow hedges that will be reclassified into earnings in the next 12 months is $14 million, based on current LIBOR interest rates.
See Note 14 for the fair value of our derivative assets and liabilities.
PART II ITEM 8 Financial Statements and Supplementary Data
## Table 5 ##
Long-Lived Assets(d)

<table><tr><td>($ in millions)</td><td>As Adjusted for Accounting Change</td></tr><tr><td>Balance at January 1, 2007</td><td>$45.8</td></tr><tr><td>Additions based on tax positions related to the current year</td><td>3.9</td></tr><tr><td>Additions for tax positions of prior years</td><td>7.6</td></tr><tr><td>Reductions for settlements</td><td>-18.4</td></tr><tr><td>Effect of foreign currency exchange rates</td><td>2.2</td></tr><tr><td>Balance at December 31, 2007</td><td>$41.1</td></tr><tr><td>Balance sheet classification:</td><td></td></tr><tr><td>Income taxes payable</td><td>$4.2</td></tr><tr><td>Deferred taxes and other liabilities</td><td>36.9</td></tr><tr><td>Total</td><td>$41.1</td></tr></table>
<table><tr><td></td><td colspan="5">% Change</td></tr><tr><td></td><td>System Sales, Ex FX</td><td>Same-Store Sales</td><td>Net New Units</td><td>GAAP Operating Profit</td><td>Core Operating Profit</td></tr><tr><td>KFC Division</td><td>+6</td><td>+3</td><td>+4</td><td>+13</td><td>+12</td></tr><tr><td>Pizza Hut Division</td><td>+1</td><td>Even</td><td>+2</td><td>-7</td><td>-6</td></tr><tr><td>Taco Bell Division</td><td>+5</td><td>+4</td><td>+4</td><td>+4</td><td>+4</td></tr><tr><td>Worldwide</td><td>+4</td><td>+2</td><td>+3</td><td>+64</td><td>+7</td></tr></table>
<table><tr><td></td><td colspan="5">2016 vs. 2015</td></tr><tr><td>Income / (Expense)</td><td>2015</td><td>Store Portfolio Actions</td><td>Other</td><td>53<sup>rd</sup>Week</td><td>2016</td></tr><tr><td>Company sales</td><td>$1,544</td><td>$-37</td><td>$9</td><td>$24</td><td>$1,540</td></tr><tr><td>Cost of sales</td><td>-422</td><td>11</td><td>20</td><td>-6</td><td>-397</td></tr><tr><td>Cost of labor</td><td>-427</td><td>10</td><td>-19</td><td>-7</td><td>-443</td></tr><tr><td>Occupancy and other</td><td>-351</td><td>7</td><td>-10</td><td>-4</td><td>-358</td></tr><tr><td>Company restaurant expense</td><td>$-1,200</td><td>$28</td><td>$-9</td><td>$-17</td><td>$-1,198</td></tr><tr><td>Restaurant profit</td><td>$344</td><td>$-9</td><td>$—</td><td>$7</td><td>$342</td></tr></table>
<table><tr><td></td><td></td><td></td><td></td><td colspan="4">% B/(W)</td></tr><tr><td>Income/(Expense)</td><td>2017</td><td>2016</td><td>2015</td><td colspan="2">2017</td><td colspan="2">2016</td></tr><tr><td>Corporate and unallocated G&A</td><td>$-230</td><td>$-280</td><td>$-180</td><td>18</td><td></td><td>-56</td><td></td></tr><tr><td>Unallocated restaurant costs</td><td>10</td><td>—</td><td>—</td><td>NM</td><td></td><td>NM</td><td></td></tr><tr><td>Unallocated Franchise and license fees and income</td><td>-5</td><td>-2</td><td>—</td><td>NM</td><td></td><td>NM</td><td></td></tr><tr><td>Unallocated Franchise and license expenses</td><td>-30</td><td>-24</td><td>-71</td><td>-26</td><td></td><td>67</td><td></td></tr><tr><td>Refranchising gain (loss) (See Note 5)</td><td>1,083</td><td>163</td><td>-23</td><td>NM</td><td></td><td>NM</td><td></td></tr><tr><td>Unallocated Other income (expense)</td><td>-8</td><td>-8</td><td>-24</td><td>3</td><td></td><td>65</td><td></td></tr><tr><td>Other pension income (expense) (See Note 15)</td><td>-47</td><td>-32</td><td>-40</td><td>-45</td><td></td><td>18</td><td></td></tr><tr><td>Interest expense, net</td><td>-440</td><td>-305</td><td>-141</td><td>-44</td><td></td><td>-117</td><td></td></tr><tr><td>Income tax provision (See Note 18)</td><td>-934</td><td>-327</td><td>-327</td><td>NM</td><td></td><td>—</td><td></td></tr><tr><td>Effective tax rate (See Note 18)</td><td>41.1%</td><td>24.3%</td><td>26.1%</td><td>-16.8</td><td>ppts.</td><td>1.8</td><td>ppts.</td></tr></table>
<table><tr><td></td><td colspan="2">Gains/(Losses) Recognized in AOCI</td><td colspan="2">(Gains)/Losses Reclassified from AOCI into Net Income</td></tr><tr><td></td><td>2017</td><td>2016</td><td>2017</td><td>2016</td></tr><tr><td>Interest rate swaps</td><td>$4</td><td>$47</td><td>$2</td><td>$- 4</td></tr><tr><td>Foreign currency contracts</td><td>- 56</td><td>10</td><td>56</td><td>- 18</td></tr><tr><td>Income tax benefit/(expense)</td><td>1</td><td>- 20</td><td>- 3</td><td>4</td></tr></table>
<table><tr><td></td><td colspan="2">Identifiable Assets</td></tr><tr><td></td><td>2017</td><td>2016</td></tr><tr><td>KFC Division<sup>(e)</sup></td><td>$1,791</td><td>$2,158</td></tr><tr><td>Pizza Hut Division<sup>(e)</sup></td><td>628</td><td>639</td></tr><tr><td>Taco Bell Division<sup>(e)</sup></td><td>1,086</td><td>1,178</td></tr><tr><td>Corporate<sup>(c)(e)</sup></td><td>1,806</td><td>1,478</td></tr><tr><td></td><td>$5,311</td><td>$5,453</td></tr></table>

Question: what percentage of total unrecognized tax benefits as of december 31 , 2007 would affect taxes should it be recognized?