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Taxation
 6 Months Ended
Jun. 30, 2011
Taxation  
Taxation

NOTE 6—TAXATION

A roll-forward of unrecognized tax benefits and associated accrued interest and penalties is as follows:

 

(in millions)

    Interest and
Penalties		     Unrecognized
Tax Benefits		     Total  

Opening balance at January 1, 2011

    $ 0.3      $ 8.3      $ 8.6   

Additions for tax positions of prior periods

      0.1        0.0        0.1   
  

 

 

    

 

 

    

 

 

  

Closing balance at June 30, 2011

      0.4        8.3        8.7   

Current

      (0.2 )      (2.0 )      (2.2 ) 
  

 

 

    

 

 

    

 

 

  

Non-current

    $ 0.2      $ 6.3      $ 6.5   
  

 

 

    

 

 

    

 

 

  

All of the $8.7 million of unrecognized tax benefits, and interest and penalties, would impact our effective tax rate if recognized.

We recognize accrued interest and penalties associated with uncertain tax positions as part of income taxes in our consolidated statements of income.

The Company or one of its subsidiaries files income tax returns in the U.S. federal jurisdiction, and various state and foreign jurisdictions. As at June 30, 2011, the Company's subsidiaries in the U.S. are subject to state tax audits in various states. The Company does not anticipate that adjustments arising out of these state tax audits would result in a material change to its financial position as at June 30, 2011.

The Company and its U.S. subsidiaries remain open to examination by the IRS for years 1998 onwards due to the net operating losses in the period 1998 to 2002, although no examination is currently underway. The Company's subsidiaries in foreign tax jurisdictions are open to examination including France (2008 onwards), Germany (2005 onwards), Switzerland (2009 onwards) and the United Kingdom (2007 onwards).