ENTECH SOLAR, INC. - FORM S-1/A - EX-8.1 - OPINION OF SALVO LANDAU GRUEN & ROGERS REGARDING CERTAIN TAX CONSEQUENCES - October 23, 2009

Attached files

file filename
S-1/A - AMENDMENT NO.3 TO FORM S-1 - ENTECH SOLAR, INC.ds1a.htm
EX-99.5 - NOTICE TO STOCKHOLDERS WHO ARE ACTING AS NOMINEES - ENTECH SOLAR, INC.dex995.htm
EX-23.1 - CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM - ENTECH SOLAR, INC.dex231.htm
EX-99.2 - FORM OF EXERCISE, SALE OR TRANSFER OF SUBSCRIPTION RIGHTS - ENTECH SOLAR, INC.dex992.htm
EX-99.7 - BENEFICIAL OWNER ELECTION FORM - ENTECH SOLAR, INC.dex997.htm
EX-99.8 - NOTICE OF GUARANTEED DELIVERY - ENTECH SOLAR, INC.dex998.htm
EX-99.1 - SUBSCRIPTION RIGHTS CERTIFICATE - ENTECH SOLAR, INC.dex991.htm
EX-99.3 - LETTER FROM FRANK W. SMITH, CEO, ENTECH SOLAR, INC. - ENTECH SOLAR, INC.dex993.htm
EX-99.4 - NOTICE TO STOCKHOLDERS WHO ARE RECORD HOLDERS - ENTECH SOLAR, INC.dex994.htm
EX-99.6 - NOTICE TO CLIENTS OF STOCKHOLDERS WHO ARE ACTING AS NOMINEES - ENTECH SOLAR, INC.dex996.htm
EX-10.32 - CONVERTIBLE PROMISSORY NOTE - ENTECH SOLAR, INC.dex1032.htm
EX-10.30 - SUBSCRIPTION AGENT AGREEMENT - ENTECH SOLAR, INC.dex1030.htm
EX-10.31 - LETTER OF AGREEMENT - ENTECH SOLAR, INC.dex1031.htm
EX-5.1 - OPINION OF SALVO LANDAU GRUEN & ROGERS REGARDING THE VALIDITY OF THE SECURITIES - ENTECH SOLAR, INC.dex51.htm

Exhibit 8.1

October 23, 2009

Board of Directors

Entech Solar, Inc.

13301 Park Vista Boulevard, Suite 100

Forth Worth, Texas 76177

 

  Re: Registration Statement on Form S-1, as amended

Reference is made to the Registration Statement on Form S-1 (as amended through the date hereof, the “Registration Statement”) of Entech Solar, Inc., a Delaware corporation (“Entech Solar”), including the prospectus, forming a part thereof, relating to the proposed rights offering of shares of Entech Solar common stock to stockholders and transferees and the related transactions contemplated to occur prior to or contemporaneously with the rights offering.

We have participated in the preparation of the discussion set forth in the section entitled “Material U.S Federal Income Tax Consequences” in the Registration Statement. In our opinion, such discussion of those consequences, insofar as it summarizes United States federal income tax law, is accurate in all material respects.

We hereby consent to the filing of this opinion with the Securities and Exchange Commission as an exhibit to the Registration Statement, and to the references therein to us. In giving such consent, we do not thereby admit that we are in the category of persons whose consent is required under Section 7 of the Securities Act of 1933, as amended.

Very truly yours,

/s/ Salvo Landau Gruen & Rogers

ENTECH SOLAR, INC. Reports