Exhibit 8.1

September 30, 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 $9,337,000 aggregate principal amount of Medium-Term Notes, Series K, Notes Linked to the 30-Year Constant Maturity Swap Rate due September 30, 2024, as described in the Company’s Pricing Supplement No. 459 dated September 25, 2014 (“Pricing Supplement 459”) 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 459.

We hereby consent to the reference to us under the heading “United States Federal Tax Considerations” in Pricing Supplement 459 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,