19 .income taxes ( continued ) capital loss carryforwards of $ 69 million and $ 90 million , which were acquired in the bgi transaction and will expire on or before 2013 .at december 31 , 2012 and 2011 , the company had $ 95 million and $ 95 million of valuation allowances for deferred income tax assets , respectively , recorded on the consolidated statements of financial condition .the year- over-year increase in the valuation allowance primarily related to certain foreign deferred income tax assets .goodwill recorded in connection with the quellos transaction has been reduced during the period by the amount of tax benefit realized from tax-deductible goodwill .see note 9 , goodwill , for further discussion .current income taxes are recorded net in the consolidated statements of financial condition when related to the same tax jurisdiction .as of december 31 , 2012 , the company had current income taxes receivable and payable of $ 102 million and $ 121 million , respectively , recorded in other assets and accounts payable and accrued liabilities , respectively .as of december 31 , 2011 , the company had current income taxes receivable and payable of $ 108 million and $ 102 million , respectively , recorded in other assets and accounts payable and accrued liabilities , respectively .the company does not provide deferred taxes on the excess of the financial reporting over tax basis on its investments in foreign subsidiaries that are essentially permanent in duration .the excess totaled $ 2125 million and $ 1516 million as of december 31 , 2012 and 2011 , respectively .the determination of the additional deferred income taxes on the excess has not been provided because it is not practicable due to the complexities associated with its hypothetical calculation .the following tabular reconciliation presents the total amounts of gross unrecognized tax benefits : year ended december 31 , ( dollar amounts in millions ) 2012 2011 2010 .
[['( dollar amounts in millions )', 'year ended december 31 , 2012', 'year ended december 31 , 2011', 'year ended december 31 , 2010'], ['balance at january 1', '$ 349', '$ 307', '$ 285'], ['additions for tax positions of prior years', '4', '22', '10'], ['reductions for tax positions of prior years', '-1 ( 1 )', '-1 ( 1 )', '-17 ( 17 )'], ['additions based on tax positions related to current year', '69', '46', '35'], ['lapse of statute of limitations', '2014', '2014', '-8 ( 8 )'], ['settlements', '-29 ( 29 )', '-25 ( 25 )', '-2 ( 2 )'], ['positions assumed in acquisitions', '12', '2014', '4'], ['balance at december 31', '$ 404', '$ 349', '$ 307']]
included in the balance of unrecognized tax benefits at december 31 , 2012 , 2011 and 2010 , respectively , are $ 250 million , $ 226 million and $ 194 million of tax benefits that , if recognized , would affect the effective tax rate .the company recognizes interest and penalties related to income tax matters as a component of income tax expense .related to the unrecognized tax benefits noted above , the company accrued interest and penalties of $ 3 million during 2012 and in total , as of december 31 , 2012 , had recognized a liability for interest and penalties of $ 69 million .the company accrued interest and penalties of $ 10 million during 2011 and in total , as of december 31 , 2011 , had recognized a liability for interest and penalties of $ 66 million .the company accrued interest and penalties of $ 8 million during 2010 and in total , as of december 31 , 2010 , had recognized a liability for interest and penalties of $ 56 million .pursuant to the amended and restated stock purchase agreement , the company has been indemnified by barclays for $ 73 million and guggenheim for $ 6 million of unrecognized tax benefits .blackrock is subject to u.s .federal income tax , state and local income tax , and foreign income tax in multiple jurisdictions .tax years after 2007 remain open to u.s .federal income tax examination , tax years after 2005 remain open to state and local income tax examination , and tax years after 2006 remain open to income tax examination in the united kingdom .with few exceptions , as of december 31 , 2012 , the company is no longer subject to u.s .federal , state , local or foreign examinations by tax authorities for years before 2006 .the internal revenue service ( 201cirs 201d ) completed its examination of blackrock 2019s 2006 and 2007 tax years in march 2011 .in november 2011 , the irs commenced its examination of blackrock 2019s 2008 and 2009 tax years , and while the impact on the consolidated financial statements is undetermined , it is not expected to be material .in july 2011 , the irs commenced its federal income tax audit of the bgi group , which blackrock acquired in december 2009 .the tax years under examination are 2007 through december 1 , 2009 , and while the impact on the consolidated financial statements is undetermined , it is not expected to be material .the company is currently under audit in several state and local jurisdictions .the significant state and local income tax examinations are in california for tax years 2004 through 2006 , new york city for tax years 2007 through 2008 , and new jersey for tax years 2003 through 2009 .no state and local income tax audits cover years earlier than 2007 except for california , new jersey and new york city .no state and local income tax audits are expected to result in an assessment material to the consolidated financial statements. .

Question: what portion of tax benefit would affect the effective tax rate if recognized as of december 31 , 2011?
Answer: 64.8%