Attached files
| file | filename |
|---|---|
| S-1 - CAMPBELL ALTERNATIVE ASSET TRUST | v188860_s-1.htm |
| EX-23.04 - CAMPBELL ALTERNATIVE ASSET TRUST | v188860_ex23-04.htm |
| EX-23.02 - CAMPBELL ALTERNATIVE ASSET TRUST | v188860_ex23-02.htm |
| EX-5.01(A) - CAMPBELL ALTERNATIVE ASSET TRUST | v188860_ex5-01a.htm |
| EX-5.01(B) - CAMPBELL ALTERNATIVE ASSET TRUST | v188860_ex5-01b.htm |
EXHIBIT
8.01
OPINION
OF COUNSEL WITH RESPECT TO INCOME TAX CONSEQUENCES
June
25, 2010
Campbell
& Company, Inc.
Managing
Owner of
Campbell
Alternative Asset Trust
2850
Quarry Lake Drive
Baltimore,
Maryland 21209
|
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Re:
|
Registration Statement
on Form S-1
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Ladies
and Gentlemen:
We have
acted as your counsel in connection with the preparation and filing with the
Securities and Exchange Commission (the "Commission") under the Securities Act
of 1933, as amended (the "Act"), of the Registration Statement on Form S-1, on
or about June 25, 2010 (the "Registration Statement"), relating to Units of
Beneficial Interest of Campbell Alternative Asset Trust (the "Trust"), a
statutory trust organized under the Delaware Statutory Trust Act.
We have
reviewed such data, documents, questions of law and fact and other matters as we
have deemed pertinent for the purpose of this opinion. Based upon the foregoing,
we hereby confirm our opinion expressed under the caption "Federal Income Tax
Aspects" in the Prospectus (the "Prospectus") constituting a part of the
Registration Statement that the Trust is classified as a partnership and will
not be considered a publicly traded partnership taxable as a corporation for
federal income tax purposes.
We also
advise you that in our opinion the description set forth under the caption
"Federal Income Tax Aspects" in the Prospectus correctly describes (subject to
the uncertainties referred to therein) the material aspects of the federal
income tax treatment to United States tax-exempt investors, as of the date
hereof, of an investment in the Trust.
We hereby
consent to the filing of this opinion as an Exhibit to the Registration
Statement and all references to our firm included in or made a part of the
Registration Statement. 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
Act or the rules and regulations of the Commission thereunder.
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Very
truly yours,
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/s/
Sidley Austin LLP
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