According to the Formula - set out in the LTW Prospectus - the Taxes are deducted first from the Total Award before the 85 % is calculated. That is why I do not include the Tax Gross-Up in my calculation of the 85 % as you do. I use the base award of $ 419 M to calculate the 85 %. My estimate is about 18 M of 113 M LTW Holders did not " opt in ".