Attached files
file | filename |
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8-K - HYUNDAI ABS FUNDING LLC | v208703_8-k.htm |
EX-5.1 - HYUNDAI ABS FUNDING LLC | v208703_ex5-1.htm |
EXHIBIT
8.1
Mayer
Brown LLP
71
South Wacker Drive
Chicago,
Illinois 60606-4637
Main
Tel +1 312 782 0600
Main
Fax +1 312 701 7711
www.mayerbrown.com
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January
20, 2011
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Hyundai
Auto Receivables Trust 2011-A
Hyundai
ABS Funding Corporation
3161
Michelson Drive, Suite 1900
Irvine,
California 92612
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Re:
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Hyundai
Auto Receivables Trust 2011-A
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Registration
Statement on Form S-3
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Registration
No. 333-168518
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Ladies
and Gentlemen:
We hereby
confirm that the statements set forth in the Base Prospectus and the Prospectus
Supplement forming part of the Registration Statement under the headings “Summary—Tax Status” and
“Material Federal Income Tax
Consequences,” to the extent that they constitute matters of law or legal
conclusions relating to the federal tax laws of the United States, and subject
to the assumptions, qualifications, limitations and exceptions set forth in the
discussion under the foregoing headings, are the opinion of Mayer Brown
LLP.
In
addition, the opinion expressed above is subject to the following assumptions,
qualifications, limitations and exceptions:
Mayer
Brown LLP operates in combination with our associated English limited liability
partnership
and Hong
Kong partnership (and its associated entities in Asia) and is associated with
Tauil & Chequer Advogados, a Brazilian law partnership.
Hyundai
Auto Receivables Trust 2011-A
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January
20, 2011
Page
2
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The law
covered by this opinion is limited to the applicable provisions of the Internal
Revenue Code of 1986, as amended (the “Code”), Treasury
regulations (including proposed and temporary Treasury Regulations), and
interpretations of the foregoing as expressed in court decisions, administrative
determinations and the legislative history as of the date
hereof. These provisions and interpretations are subject to change,
which may or may not be retroactive in effect, that might result in
modifications of our opinion. We express no opinion as to the laws of
any other jurisdiction and, unless otherwise specified, no opinion regarding the
statutes, administrative decisions, rules, regulations or requirements of any
county, municipality, subdivision or local authority of any
jurisdiction.
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 use of our
name therein, without admitting that we are “experts” within the meaning of the
Act or the rules or regulations of the Securities and Exchange Commission
thereunder, with respect to any part of the Registration Statement, including
this exhibit.
JBO/SDG/RXG
Very
truly yours,
Mayer
Brown LLP