Attached files
| file | filename |
|---|---|
| S-1/A - United States Commodity Index Funds Trust | v190928_s1a.htm |
| EX-10.4 - United States Commodity Index Funds Trust | v190928_ex10-4.htm |
| EX-10.1 - United States Commodity Index Funds Trust | v190928_ex10-1.htm |
| EX-10.3 - United States Commodity Index Funds Trust | v190928_ex10-3.htm |
| EX-10.2 - United States Commodity Index Funds Trust | v190928_ex10-2.htm |
| EX-23.2B - United States Commodity Index Funds Trust | v190928_ex23-2b.htm |
| EX-23.2A - United States Commodity Index Funds Trust | v190928_ex23-2a.htm |
Exhibit
8.1
[Letterhead
of Sutherland, Asbill & Brennan LLP]
July 23,
2010
United
States Commodity Index Funds Trust
1320
Harbor Bay Parkway, Suite 145
Alameda,
CA 94502
|
RE:
|
United
States Commodity Index Funds Trust
|
Registration Statement on Form S-1
(File No. 333-164024)
Ladies
and Gentlemen:
We have
acted as tax counsel for the United States Commodity Index Funds Trust (the
“Trust”), a Delaware statutory trust established in series, in connection with
the offer and sale (the “Offering”) of units (the “Units”) representing
fractional undivided units of beneficial interest in United States Commodity
Index Fund, a series of the Trust (the “Fund”).
As
counsel to the Trust, we have participated in the preparation of the
registration statement for the Offering on Form S-1 (the “Registration
Statement”) to which this opinion is an exhibit, including the discussion set
forth under the caption “U.S. Federal Income Tax Considerations” (the
“Discussion”) in the Registration Statement.
The
Discussion, subject to the qualifications and assumptions stated in the
Discussion and the limitations and qualifications set forth herein, constitutes
our opinion as to the material United States federal income tax consequences for
purchasers of the Units pursuant to the Offering.
Our
opinion is based on current provisions of the U.S. Internal Revenue Code of
1986, as amended (the “Code”), applicable U.S. Treasury regulations promulgated
under the Code (the “Regulations”), and public administrative and judicial
interpretations of the Code and the Regulations as of the date hereof, all of
which are subject to change, possibly with retroactive effect. Our
opinion represents only our legal judgment based on current law and the facts as
referred to above, and has no binding effect on the U.S. Internal Revenue
Service or the courts. The U.S. Internal Revenue Service may take a
position contrary to our opinion, and if the matter is litigated, a court may
reach a decision contrary to our opinion.
Our
opinion is limited to the matters set forth herein, and no opinions are intended
to be implied or may be inferred beyond the opinion expressly stated
herein. Our opinion is rendered as of the date hereof and we assume
no obligation to update or supplement this opinion or any matter related to this
opinion to reflect any change of fact, circumstances or law after the date
hereof.
We hereby
consent to the filing of this opinion as an exhibit to the Registration
Statement and to the references to our firm and this opinion contained in the
Discussion. In giving this consent, we do not admit that we are within the
category of persons whose consent is required under Section 7 of the Securities
Act of 1933, as amended, or under the rules and regulations of the Securities
and Exchange Commission relating thereto.
|
Very
truly yours,
|
||
|
/s/
David A. Roby, Jr.
|
||
|
David
A. Roby, Jr., a partner
|