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 .

Year ended December 31,
<i>(Dollar amounts in millions)</i>
2012
2011
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)
(17)
Additions based on tax positions related to current year
69
46
35
Lapse of statute of limitations
—
—
(8)
Settlements
(29)
(25)
(2)
Positions assumed in acquisitions
12
—
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: Analyse this data from a financial earnings document. what portion of tax benefit would affect the effective tax rate if recognized as of december 31 , 2011?
Choices:
-123
0.87966
0.73616
0.64756
1.54425
Correct choice index: 3