page 62 of 94 notes to consolidated financial statements ball corporation and subsidiaries 14 . taxes on income ( continued ) at december 31 , 2007 , ball corporation and its domestic subsidiaries had net operating loss carryforwards , expiring between 2020 and 2026 , of $ 64.6 million with a related tax benefit of $ 25.2 million . also at december 31 , 2007 , ball packaging europe and its subsidiaries had net operating loss carryforwards , with no expiration date , of $ 54.4 million with a related tax benefit of $ 14.6 million . ball packaging products canada corp . had a net operating loss carryforward , with no expiration date , of $ 15.8 million with a related tax benefit of $ 5.4 million . due to the uncertainty of ultimate realization , these european and canadian benefits have been offset by valuation allowances of $ 8.6 million and $ 5.4 million , respectively . upon realization , $ 5.3 million of the european valuation allowance will be recognized as a reduction in goodwill . at december 31 , 2007 , the company has foreign tax credit carryforwards of $ 5.8 million ; however , due to the uncertainty of realization of the entire credit , a valuation allowance of $ 3.8 million has been applied to reduce the carrying value to $ 2 million . effective january 1 , 2007 , ball adopted fin no . 48 , 201caccounting for uncertainty in income taxes . 201d as of the date of adoption , the accrual for uncertain tax position was $ 45.8 million , and the cumulative effect of the adoption was an increase in the reserve for uncertain tax positions of $ 2.1 million . the accrual includes an $ 11.4 million reduction in opening retained earnings and a $ 9.3 million reduction in goodwill . a reconciliation of the unrecognized tax benefits follows : ( $ in millions ) as adjusted for accounting change .
what percentage of total unrecognized tax benefits as of december 31 , 2007 would affect taxes should it be recognized?
the amount of unrecognized tax benefits at december 31 , 2007 , that , if recognized , would reduce tax expense is $ 35.9 million . at this time there are no positions where the unrecognized tax benefit is expected to increase or decrease significantly within the next 12 months . u.s . federal and state income tax returns filed for the years 2000- 2006 are open for audit , with an effective settlement of the federal returns through 2004 . the income tax returns filed in europe for the years 2002 through 2006 are also open for audit . the company 2019s significant filings in europe are in germany , france , the netherlands , poland , serbia and the united kingdom . the company recognizes the accrual of interest and penalties related to unrecognized tax benefits in income tax expense . during the year ended december 31 , 2007 , ball recognized approximately $ 2.7 million of interest expense . the accrual for uncertain tax positions at december 31 , 2007 , includes approximately $ 5.1 million representing potential interest expense . no penalties have been accrued . the 2007 provision for income taxes included an $ 11.5 million accrual under fin no . 48 . the majority of this provision was related to the effective settlement during the third quarter of 2007 with the internal revenue service for interest deductions on incurred loans from a company-owned life insurance plan . the total accrual at december 31 , 2007 , for the effective settlement of the applicable prior years 2000-2004 under examination , and unaudited years 2005 through 2007 , was $ 18.4 million , including estimated interest . the settlement resulted in a majority of the interest deductions being sustained with prospective application that results in no significant impact to future earnings per share or cash flows. .