table of contents notes to consolidated financial statements ( continued ) note 5 2014income taxes ( continued ) fin 48 in the first quarter of 2008 , the company adopted fin 48 . upon adoption of fin 48 , the company 2019s cumulative effect of a change in accounting principle resulted in an increase to retained earnings of $ 11 million . the company had historically classified interest and penalties and unrecognized tax benefits as current liabilities . beginning with the adoption of fin 48 , the company classifies gross interest and penalties and unrecognized tax benefits that are not expected to result in payment or receipt of cash within one year as non-current liabilities in the consolidated balance sheet . the total amount of gross unrecognized tax benefits as of the date of adoption of fin 48 was $ 475 million , of which $ 209 million , if recognized , would affect the company 2019s effective tax rate . as of september 27 , 2008 , the total amount of gross unrecognized tax benefits was $ 506 million , of which $ 253 million , if recognized , would affect the company 2019s effective tax rate . the company 2019s total gross unrecognized tax benefits are classified as non-current liabilities in the consolidated balance sheet . the aggregate changes in the balance of gross unrecognized tax benefits , which excludes interest and penalties , for the fiscal year ended september 27 , 2008 , is as follows ( in millions ) : the company 2019s policy to include interest and penalties related to unrecognized tax benefits within the provision for income taxes did not change as a result of adopting fin 48 . as of the date of adoption , the company had accrued $ 203 million for the gross interest and penalties relating to unrecognized tax benefits . as of september 27 , 2008 , the total amount of gross interest and penalties accrued was $ 219 million , which is classified as non-current liabilities in the consolidated balance sheet . in 2008 , the company recognized interest expense in connection with tax matters of $ 16 million . the company is subject to taxation and files income tax returns in the u.s . federal jurisdiction and in many state and foreign jurisdictions . for u.s . federal income tax purposes , all years prior to 2002 are closed . the years 2002-2003 have been examined by the internal revenue service ( the 201cirs 201d ) and disputed issues have been taken to administrative appeals . the irs is currently examining the 2004-2006 years . in addition , the company is also subject to audits by state , local , and foreign tax authorities . in major states and major foreign jurisdictions , the years subsequent to 1988 and 2000 , respectively , generally remain open and could be subject to examination by the taxing authorities . management believes that an adequate provision has been made for any adjustments that may result from tax examinations . however , the outcome of tax audits cannot be predicted with certainty . if any issues addressed in the company 2019s tax audits are resolved in a manner not consistent with management 2019s expectations , the company could be required to adjust its provision for income tax in the period such resolution occurs . although timing of the resolution and/or closure of audits is highly uncertain , the company does not believe it is reasonably possible that its unrecognized tax benefits would materially change in the next 12 months. .
what is the net of increases related to tax positions taken during a prior period and decreases related to tax positions taken during a prior period , in millions?
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