Uncertain tax benefits reduce deferred tax assets to the extent the uncertainty directly related to that asset; otherwise, they are  recognized as either current or non-current U.S. and foreign income taxes payable. Accrued interest and penalties payable for  unrecognized tax benefits are included in either current or non-current U.S. and foreign income taxes payable. Interest and penalties  related to unrecognized tax benefits are included in income tax expense.  BMS is currently under examination by a number of tax authorities, including but not limited to the major tax jurisdictions listed in the  table below, which have proposed adjustments to tax for issues such as transfer pricing, certain tax credits and the deductibility of  certain expenses. BMS estimates that it is reasonably possible that the total amount of unrecognized tax benefits at December 31,  2012 will decrease in the range of approximately $370 million to $400 million in the next twelve months as a result of the settlement  of certain tax audits and other events. The expected change in unrecognized tax benefits, primarily settlement related, will involve the  payment of additional taxes, the adjustment of certain deferred taxes and/or the recognition of tax benefits. BMS also anticipates that  it is reasonably possible that new issues will be raised by tax authorities which may require increases to the balance of unrecognized  tax benefits; however, an estimate of such increases cannot reasonably be made at this time. BMS believes that it has adequately  provided for all open tax years by tax jurisdiction.  The following is a summary of major tax jurisdictions for which tax authorities may assert additional taxes based upon tax years  currently under audit and subsequent years that will likely be audited:  48 Year Ended December 31, Amounts in Millions, Except Per Share Data 2012 2011 2010 Net Earnings Attributable to BMS $  1,960  $   3,709 $  3,102 Earnings attributable to unvested restricted shares   (1)  (8)  (12) Net Earnings Attributable to BMS common shareholders  $  1,959  $   3,701 $  3,090 Earnings per share - basic  $  1.17  $   2.18 $  1.80 Weighted-average common shares outstanding - basic   1,670   1,700  1,713 Contingently convertible debt common stock equivalents   1   1  1 Incremental shares attributable to share-based compensation plans   17   16  13 Weighted-average common shares outstanding - diluted   1,688   1,717  1,727 Earnings per share - diluted  $  1.16  $   2.16 $  1.79 Anti-dilutive weighted-average equivalent shares - stock incentive plans   2   13  51 Note 8 EARNINGS PER SHARE  U.S.  2008 to 2012  Canada  2005 to 2012  France  2010 to 2012  Germany  2007 to 2012  Italy  2003 to 2012  Mexico  2006 to 2012  Year Ended December 31, Dollars in Millions 2012 2011 2010  Unrecognized tax benefits that if recognized would impact the effective tax rate $  633  $   570 $  818  Accrued interest   59   51  51  Accrued penalties   32   25  23  Interest expense/(benefit)   14   10  (12) Penalty expense/(benefit)   16   7  (4) Additional information regarding unrecognized tax benefits is as follows:  Bristol-Myers Squibb 