Exhibit 8.1

Apartment Investment and Management Company

4582 S. Ulster Street

Suite 1100

Denver, Colorado 80237

Ladies and Gentlemen:

You have requested our opinion concerning certain U.S. federal income tax considerations in connection with the offering (the “Offering”) of up to 12,391,934 shares of Class A common stock (the “Class A Common Stock”) of Apartment Investment and Management Company, a Maryland corporation (“AIMCO”), pursuant to a registration statement on Form S-3 (Registration No. 333-173503) filed by AIMCO with the Securities and Exchange Commission (the “Commission”) on April 14, 2011 (such Registration Statement, as so amended, the “Registration Statement”), the prospectus, dated April 14, 2011, included with the Registration Statement (the “Base Prospectus”), the preliminary prospectus supplement dated June 20, 2012 (the “Preliminary Prospectus Supplement”) and the prospectus supplement dated June 25, 2012 (together with the Base Prospectus and the Preliminary Prospectus Supplement, the “Prospectus”). All capitalized terms used herein, unless otherwise specified, shall have the meanings assigned to them in the Prospectus.

In connection with the Offering and with certain previous offerings of AIMCO stock and securities, we have acted as counsel to AIMCO, and we have assisted in the preparation of the Registration Statement, the Prospectus and certain other documents. In formulating our opinion, we have examined and relied on originals or copies, certified or otherwise identified to our satisfaction, of the Registration Statement, the Prospectus and such other documentation and information provided by AIMCO as is relevant to the Offering and

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June 25, 2012

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necessary to prepare the Registration Statement and the Prospectus or as we have deemed necessary or appropriate as a basis for the opinion set forth herein. In addition, AIMCO has provided us with certain representations and covenants of officers of AIMCO relating to, among other things, properties, assets, income, distributions, stockholder ownership, organizational structure and other requirements, and the past, present and future conduct of AIMCO’s business operations. We have assumed that such statements, representations and covenants are true as of the date hereof, and will continue to be true, without regard to any qualification as to knowledge and belief. For purposes of our opinion, we have not assumed any responsibility for investigating or independently verifying the facts and representations set forth in such documents, the partnership agreements and organizational documents for each of the corporations, partnerships and limited liability companies in which AIMCO holds a direct or indirect interest (the “Subsidiaries”), the Registration Statement, the Prospectus, or any other document, and we have not undertaken any independent review of such information. In particular, we note that AIMCO engages in transactions in connection with which we have not provided legal advice, and have not reviewed, and of which we may be unaware. We have, consequently, assumed and relied on AIMCO’s representations that the information presented in such documents or otherwise furnished to us accurately and completely describes all material facts relevant to our opinion.

In rendering our opinion, we have assumed that the transactions contemplated by the foregoing documents have been or will be consummated in accordance with the operative documents, and that such documents accurately reflect the material facts of such transactions. In addition, our opinion is based on the correctness of the assumption that there have been no changes in the applicable laws of the State of Maryland or any other state under the laws of which any of the Subsidiaries have been formed. In rendering our opinion, we have also considered and relied upon the Internal Revenue Code of 1986, as amended (the “Code”), the regulations promulgated thereunder (the “Regulations”), administrative rulings and other interpretations of the Code and the Regulations by the courts and the Internal Revenue Service, all as they exist as of the date hereof. It should be noted that the Code, Regulations, judicial decisions, and administrative interpretations are subject to change at any time (possibly with retroactive effect). Any change which is made after the date hereof in any of the foregoing bases for our opinion could affect our conclusions herein. There can be no assurances, moreover, that any of the opinions expressed herein will be accepted by the Internal Revenue Service or, if challenged, by a court.

Based upon and subject to the foregoing, for U.S. federal income tax purposes we are of the opinion that:

1. Commencing with AIMCO’s initial taxable year ended December 31, 1994, AIMCO was organized in conformity with the requirements for qualification as a REIT under the Code, and its actual method of operation has enabled, and its proposed method of operation will enable, AIMCO to meet the requirements for qualification and taxation as a REIT under the Code. AIMCO’s qualification and taxation as a REIT depend upon its ability to meet, through

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actual annual operating results, certain requirements including requirements relating to distribution levels and diversity of stock ownership, and the various qualification tests imposed under the Code, the results of which are not reviewed by us. Accordingly, no assurance can be given that the actual results of AIMCO’s operation for any particular taxable year satisfy the requirements for taxation as a REIT under the Code.

2. Although the discussion set forth in the Base Prospectus under the caption “Material United States Federal Income Tax Considerations” does not purport to discuss all possible U.S. federal income tax consequences of the acquisition, ownership, and disposition of the Class A Common Stock, the discussion, although general in nature, constitutes, in all material respects, a fair and accurate summary under current law of certain material U.S. federal income tax consequences of the acquisition, ownership and disposition of the Class A Common Stock by a holder who acquires such Class A Common Stock, subject to the qualifications set forth therein. The U.S. federal income tax consequences of an investment in the Class A Common Stock by an investor will depend upon that holder’s particular situation, and we express no opinion as to the completeness of the discussion set forth in “Material United States Federal Income Tax Considerations” as applied to any particular holder.

Other than as expressly stated above, we express no opinion on any issue relating to AIMCO or to any investment therein.

This opinion has been prepared for you in connection with the transaction described herein. We consent to the reference to Skadden, Arps, Slate, Meagher & Flom LLP under the caption “Legal Matters” in the Registration Statement and the Prospectus. In giving this consent, we do not thereby admit that we are within the category of persons whose consent is required under Section 7 of the Securities Act, or the rules and regulations of the Commission. This opinion is expressed as of the date hereof, and we are under no obligation to supplement or revise our opinion to reflect any legal developments or factual matters arising subsequent to the date hereof, or the impact of any information, document, certificate, record, statement, representation, covenant, or assumption relied upon herein that becomes incorrect or untrue.

Very truly yours,

/s/ Skadden, Arps, Slate, Meagher & Flom LLP