Attached files
| file | filename |
|---|---|
| 8-K - FORM 8-K - WELLS FARGO & COMPANY/MN | d749517d8k.htm |
| EX-5.1 - OPINION OF FAEGRE BAKER DANIELS LLP REGARDING THE NOTES - WELLS FARGO & COMPANY/MN | d749517dex51.htm |
| EX-4.1 - FORM OF MEDIUM-TERM NOTES, SERIES K - WELLS FARGO & COMPANY/MN | d749517dex41.htm |
Exhibit 8.1
| New York Menlo Park Washington DC São Paulo London |
Paris Madrid Tokyo Beijing Hong Kong |
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| Davis Polk & Wardwell LLP 450 Lexington Avenue New York, NY 10017 |
212 450 4000 tel 212 701 5800 fax |
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July 1, 2014
Wells Fargo & Company,
420 Montgomery Street,
San Francisco, California 94104
Ladies and Gentlemen:
We have acted as special tax counsel to Wells Fargo & Company, a Delaware corporation (the “Company”), in connection with the issuance of $40,001,664.90 aggregate face amount of Medium-Term Notes, Series K, 8% Equity Linked Securities due June 18, 2015, Linked to the Common Stock of Micron Technology, Inc., as described in the Company’s Pricing Supplement No. 440 dated June 24, 2014 (“Pricing Supplement 440”) to the Prospectus Supplement dated April 13, 2012 and the Prospectus dated April 13, 2012 contained in the Registration Statement on Form S-3, File No. 333-180728 (the “Registration Statement”). We hereby confirm our opinion as set forth under the heading “United States Federal Tax Considerations” in Pricing Supplement 440.
We hereby consent to the reference to us under the heading “United States Federal Tax Considerations” in Pricing Supplement 440 and to the filing of this opinion as an exhibit to a Current Report on Form 8-K of the Company filed with the Securities and Exchange Commission and thereby incorporated by reference into the Company’s Registration Statement. In giving such 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.
Very truly yours,
/s/ Davis Polk & Wardwell LLP
Davis Polk & Wardwell LLP