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 .

Table: ( 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%
Calculation: divide(226, 349)