SOUTHERN CALIFORNIA EDISON Co - FORM 8-K - EX-8.1 - OPINION OF MUNGER, TOLLES & OLSON LLP AS TO CERTAIN TAX MATTERS - May 17, 2012

Attached files

file filename
8-K - FORM 8-K - SOUTHERN CALIFORNIA EDISON Cosce8k5102012.htm
EX-4.3 - GUARANTEE, DATED MAY 17, 2012 BY THE COMPANY - SOUTHERN CALIFORNIA EDISON Coexhibit43.htm
EX-5.3 - OPINION OF MUNGER, TOLLES & OLSON LLP, DATED MAY 17, 2012 - SOUTHERN CALIFORNIA EDISON Coexhibit53.htm
EX-5.1 - OPINION OF RICHARDS, LAYTON & FINGER, P.A., DATED MAY 17, 2012 - SOUTHERN CALIFORNIA EDISON Coexhibit51.htm
EX-4.1 - CERTIFICATE OF DETERMINATION OF PREFERENCES OF THE SERIES F PREFERENCE STOCK - SOUTHERN CALIFORNIA EDISON Coexhibit41.htm
EX-4.2 - AMENDED AND RESTATED DECLARATION OF TRUST OF SCE TRUST I - SOUTHERN CALIFORNIA EDISON Coexhibit42.htm
EX-5.2 - OPINION OF BARBARA E. MATHEWS, DATED MAY 17, 2012 - SOUTHERN CALIFORNIA EDISON Coexhibit52.htm
EX-1.1 - UNDERWRITING AGREEMENT AMONG THE COMPANY, THE TRUST AND THE TRUSTEES NAMED THEREIN DATED AS OF MAY 11, 2012 - SOUTHERN CALIFORNIA EDISON Coexhibit11.htm
EX-12.1 - STATEMENT RE COMPUTATION OF RATIOS TO EARNINGS TO FIXED CHARGES AND PREFERRED EQUITY DIVIDENDS - SOUTHERN CALIFORNIA EDISON Coexhibit121.htm
EX-12.2 - STATEMENT RE COMPUTATION OF RATIOS OF EARNINGS TO FIXED CHARGES - SOUTHERN CALIFORNIA EDISON Coexhibit122.htm
Exhibit 8.1
 
 

OPINION OF MUNGER, TOLLES & OLSON LLP
AS TO CERTAIN TAX MATTERS

May 17, 2012

Southern California Edison Company
SCE Trust I
2244 Walnut Grove Avenue
Rosemead, California 91770

Ladies and Gentlemen:

As special tax counsel to Southern California Edison Company, a California corporation and SCE Trust I, a Delaware statutory trust (the “Trust”), in connection with the issuance by the Trust of $475,000,000 of its 5.625% Trust Preference Securities (the “Trust Preference Securities”), as described in that certain prospectus dated May 10, 2012 (the “Prospectus”), we hereby confirm to you our opinion as set forth under the heading “Material U.S. Federal Income Tax Considerations” in the Prospectus, subject to the limitations set forth therein.

We hereby consent to the filing of this opinion as an exhibit to the Prospectus and to the reference to us under the heading “Material U.S. Federal Income Tax Considerations” in the Prospectus. 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.

 
 
 
   Very truly yours,
 
 
 
  /s/ MUNGER, TOLLES & OLSON LLP
 
 
 
 
        
                                         


 
 

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