a reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows: .
what was the ratio of interest and penalties associated with uncertain tax positions in 2013 to 2012
( 1 ) amounts reflect the settlements with the irs and cra as discussed below . if the company were to recognize the unrecognized tax benefits of $ 3.5 billion at december 31 , 2013 , the income tax provision would reflect a favorable net impact of $ 3.3 billion . the company is under examination by numerous tax authorities in various jurisdictions globally . the company believes that it is reasonably possible that the total amount of unrecognized tax benefits as of december 31 , 2013 could decrease by up to $ 128 million in the next 12 months as a result of various audit closures , settlements or the expiration of the statute of limitations . the ultimate finalization of the company 2019s examinations with relevant taxing authorities can include formal administrative and legal proceedings , which could have a significant impact on the timing of the reversal of unrecognized tax benefits . the company believes that its reserves for uncertain tax positions are adequate to cover existing risks or exposures . interest and penalties associated with uncertain tax positions amounted to a benefit of $ 319 million in 2013 , $ 88 million in 2012 and $ 95 million in 2011 . these amounts reflect the beneficial impacts of various tax settlements , including those discussed below . liabilities for accrued interest and penalties were $ 665 million and $ 1.2 billion as of december 31 , 2013 and 2012 , respectively . in 2013 , the internal revenue service ( 201cirs 201d ) finalized its examination of schering-plough 2019s 2007-2009 tax years . the company 2019s unrecognized tax benefits for the years under examination exceeded the adjustments related to this examination period and therefore the company recorded a net $ 165 million tax provision benefit in 2013 . in 2010 , the irs finalized its examination of schering-plough 2019s 2003-2006 tax years . in this audit cycle , the company reached an agreement with the irs on an adjustment to income related to intercompany pricing matters . this income adjustment mostly reduced nols and other tax credit carryforwards . the company 2019s reserves for uncertain tax positions were adequate to cover all adjustments related to this examination period . additionally , as previously disclosed , the company was seeking resolution of one issue raised during this examination through the irs administrative appeals process . in 2013 , the company recorded an out-of-period net tax benefit of $ 160 million related to this issue , which was settled in the fourth quarter of 2012 , with final resolution relating to interest owed being reached in the first quarter of 2013 . the company 2019s unrecognized tax benefits related to this issue exceeded the settlement amount . management has concluded that the exclusion of this benefit is not material to current or prior year financial statements . as previously disclosed , the canada revenue agency ( the 201ccra 201d ) had proposed adjustments for 1999 and 2000 relating to intercompany pricing matters and , in july 2011 , the cra issued assessments for other miscellaneous audit issues for tax years 2001-2004 . in 2012 , merck and the cra reached a settlement for these years that calls for merck to pay additional canadian tax of approximately $ 65 million . the company 2019s unrecognized tax benefits related to these matters exceeded the settlement amount and therefore the company recorded a net $ 112 million tax provision benefit in 2012 . a portion of the taxes paid is expected to be creditable for u.s . tax purposes . the company had previously established reserves for these matters . the resolution of these matters did not have a material effect on the company 2019s results of operations , financial position or liquidity . in 2011 , the irs concluded its examination of merck 2019s 2002-2005 federal income tax returns and as a result the company was required to make net payments of approximately $ 465 million . the company 2019s unrecognized tax benefits for the years under examination exceeded the adjustments related to this examination period and therefore the company recorded a net $ 700 million tax provision benefit in 2011 . this net benefit reflects the decrease of unrecognized tax benefits for the years under examination partially offset by increases to unrecognized tax benefits for years subsequent table of contents .