uncertain tax positions the following is a reconciliation of the company's beginning and ending amount of uncertain tax positions ( in millions ) : .

Table:
 | 2015 | 2014
balance at january 1 | $ 191 | $ 164
additions based on tax positions related to the current year | 31 | 31
additions for tax positions of prior years | 53 | 10
reductions for tax positions of prior years | -18 ( 18 ) | -6 ( 6 )
settlements | -32 ( 32 ) | 2014
business combinations | 2014 | 5
lapse of statute of limitations | -5 ( 5 ) | -11 ( 11 )
foreign currency translation | -2 ( 2 ) | -2 ( 2 )
balance at december 31 | $ 218 | $ 191
the company's liability for uncertain tax positions as of december 31 , 2015 , 2014 , and 2013 , includes $ 180 million , $ 154 million , and $ 141 million , respectively , related to amounts that would impact the effective tax rate if recognized .
it is possible that the amount of unrecognized tax benefits may change in the next twelve months ; however , we do not expect the change to have a significant impact on our consolidated statements of income or consolidated balance sheets .
these changes may be the result of settlements of ongoing audits .
at this time , an estimate of the range of the reasonably possible outcomes within the twelve months cannot be made .
the company recognizes interest and penalties related to uncertain tax positions in its provision for income taxes .
the company accrued potential interest and penalties of $ 2 million , $ 4 million , and $ 2 million in 2015 , 2014 , and 2013 , respectively .
the company recorded a liability for interest and penalties of $ 33 million , $ 31 million , and $ 27 million as of december 31 , 2015 , 2014 , and 2013 , respectively .
the company and its subsidiaries file income tax returns in their respective jurisdictions .
the company has substantially concluded all u.s .
federal income tax matters for years through 2007 .
material u.s .
state and local income tax jurisdiction examinations have been concluded for years through 2005 .
the company has concluded income tax examinations in its primary non-u.s .
jurisdictions through 2005 .
9 .
shareholders' equity distributable reserves as a u.k .
incorporated company , the company is required under u.k .
law to have available "distributable reserves" to make share repurchases or pay dividends to shareholders .
distributable reserves may be created through the earnings of the u.k .
parent company and , amongst other methods , through a reduction in share capital approved by the english companies court .
distributable reserves are not linked to a u.s .
gaap reported amount ( e.g. , retained earnings ) .
as of december 31 , 2015 and 2014 , the company had distributable reserves in excess of $ 2.1 billion and $ 4.0 billion , respectively .
ordinary shares in april 2012 , the company's board of directors authorized a share repurchase program under which up to $ 5.0 billion of class a ordinary shares may be repurchased ( "2012 share repurchase program" ) .
in november 2014 , the company's board of directors authorized a new $ 5.0 billion share repurchase program in addition to the existing program ( "2014 share repurchase program" and , together , the "repurchase programs" ) .
under each program , shares may be repurchased through the open market or in privately negotiated transactions , based on prevailing market conditions , funded from available capital .
during 2015 , the company repurchased 16.0 million shares at an average price per share of $ 97.04 for a total cost of $ 1.6 billion under the repurchase programs .
during 2014 , the company repurchased 25.8 million shares at an average price per share of $ 87.18 for a total cost of $ 2.3 billion under the 2012 share repurchase plan .
in august 2015 , the $ 5 billion of class a ordinary shares authorized under the 2012 share repurchase program was exhausted .
at december 31 , 2015 , the remaining authorized amount for share repurchase under the 2014 share repurchase program is $ 4.1 billion .
under the repurchase programs , the company repurchased a total of 78.1 million shares for an aggregate cost of $ 5.9 billion. .

Question: what is the difference between the liability for uncertain tax positions as of december 31 , 2015 and the balance of the uncertain tax positions at december 31 , 2015 , ( in millions )
Answer: 38
Calculation: subtract(218, 180)