kimco realty corporation and subsidiaries notes to consolidated financial statements , continued uncertain tax positions : the company is subject to income tax in certain jurisdictions outside the u.s. , principally canada and mexico . the statute of limitations on assessment of tax varies from three to seven years depending on the jurisdiction and tax issue . tax returns filed in each jurisdiction are subject to examination by local tax authorities . the company is currently under audit by the canadian revenue agency , mexican tax authority and the u.s . internal revenue service ( 201cirs 201d ) . in october 2011 , the irs issued a notice of proposed adjustment , which proposes pursuant to section 482 of the code , to disallow a capital loss claimed by krs on the disposition of common shares of valad property ltd. , an australian publicly listed company . because the adjustment is being made pursuant to section 482 of the code , the irs believes it can assert a 100 percent 201cpenalty 201d tax pursuant to section 857 ( b ) ( 7 ) of the code and disallow the capital loss deduction . the notice of proposed adjustment indicates the irs 2019 intention to impose the 100 percent 201cpenalty 201d tax on the company in the amount of $ 40.9 million and disallowing the capital loss claimed by krs . the company and its outside counsel have considered the irs 2019 assessment and believe that there is sufficient documentation establishing a valid business purpose for the transfer , including recent case history showing support for similar positions . accordingly , the company strongly disagrees with the irs 2019 position on the application of section 482 of the code to the disposition of the shares , the imposition of the 100 percent penalty tax and the simultaneous assertion of the penalty tax and disallowance of the capital loss deduction . the company received a notice of proposed assessment and filed a written protest and requested an irs appeals office conference . an appeals hearing was attended by management and its attorneys , the irs compliance group and an irs appeals officer in november , 2014 , at which time irs compliance presented arguments in support of their position , as noted herein . management and its attorneys presented rebuttal arguments in support of its position . the matter is currently under consideration by the appeals officer . the company intends to vigorously defend its position in this matter and believes it will prevail . resolutions of these audits are not expected to have a material effect on the company 2019s financial statements . during 2013 , the company early adopted asu 2013-11 prospectively and reclassified a portion of its reserve for uncertain tax positions . the reserve for uncertain tax positions included amounts related to the company 2019s canadian operations . the company has unrecognized tax benefits reported as deferred tax assets and are available to settle adjustments made with respect to the company 2019s uncertain tax positions in canada . the company reduced its reserve for uncertain tax positions by $ 12.3 million associated with its canadian operations and reduced its deferred tax assets in accordance with asu 2013-11 . the company does not believe that the total amount of unrecognized tax benefits as of december 31 , 2014 , will significantly increase or decrease within the next 12 months . as of december 31 , 2014 , the company 2019s canadian uncertain tax positions , which reduce its deferred tax assets , aggregated $ 10.4 million . the liability for uncertain tax benefits principally consists of estimated foreign , federal and state income tax liabilities in years for which the statute of limitations is open . open years range from 2008 through 2014 and vary by jurisdiction and issue . the aggregate changes in the balance of unrecognized tax benefits for the years ended december 31 , 2014 and 2013 were as follows ( in thousands ) : .
what is the proportion of dollars at the beginning of both combined years to dollars at end of both combined years?
( a ) this amount was reclassified against the related deferred tax asset relating to the company 2019s early adoption of asu 2013-11 as discussed above. .