to the recognition of a valuation allowance on deferred tax assets (refer to Note 14 of Notes to Consolidated Financial Statements); and 

a net tax benefit of approximately $13 million related to amounts required to be recorded for changes to our uncertain tax positions, including interest and penalties (refer to Note 14 of Notes to Consolidated Financial Statements). 

Our effective tax rate of approximately 21.7 percent for the year ended December 31, 2008, included the following: 

an approximate 20 percent combined effective tax rate on restructuring charges, other-than-temporary impairments of available-for-sale securities, contract termination fees, productivity initiatives and asset impairments recorded by the Company (refer to Note 17 of Notes to Consolidated Financial Statements); 

an approximate 23 percent combined effective tax rate on our proportionate share of asset impairment and restructuring charges recorded by equity method investees, primarily related to impairment charges recorded by CCE (refer to Note 17 of Notes to Consolidated Financial Statements); 

an approximate 24 percent combined effective tax rate on gains from divestitures (refer to Note 17 of Notes to Consolidated Financial Statements); 

a tax charge of approximately $10 million related to the recognition of a valuation allowance on deferred tax assets (refer to Note 14 of Notes to Consolidated Financial Statements); and 

a net tax benefit of approximately $5 million, primarily related to amounts required to be recorded for changes to our uncertain tax positions, including interest and penalties (refer to Note 14 of Notes to Consolidated Financial Statements). 

As of December 31, 2010, the gross amount of unrecognized tax benefits was approximately $387 million. If the Company were to prevail on all uncertain tax positions, the net effect would be a benefit to the Company's effective tax rate of approximately $163 million, exclusive of any benefits related to interest and penalties. The remaining approximately $224 million, which was recorded as a deferred tax asset, primarily represents tax benefits that would be received in different tax jurisdictions in the event that the Company did not prevail on all uncertain tax positions. Refer to Note 14 of Notes to Consolidated Financial Statements. A reconciliation of the changes in the gross balance of unrecognized tax benefit amounts is as follows (in millions): 

In 2008, agreements were reached between the U.S. government and a foreign government concerning the allocation of income between the two tax jurisdictions. Pursuant to these agreements, we made cash payments during the third quarter of 2008 that constituted payments of tax and interest. These payments were partially offset by tax credits taken in the third quarter and fourth quarter of 2008, and tax refunds and interest on refunds received in 2009. These benefits had been recorded as deferred tax assets in prior periods. The settlements did not have a material impact on the Company's consolidated income statement for the year ended December 31, 2008. 

The Company recognizes accrued interest and penalties related to unrecognized tax benefits in