EXHIBIT 8.1
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Mayer Brown LLP 350 South Grand Avenue 25th Floor Los Angeles, California 90071-1503 Main Tel (213) 229-9500 Main Fax (213) 625-0248 www.mayerbrown.com | |
September 19, 2007 | |
Hyundai Auto Receivables Trust 2007-A Hyundai ABS Funding Corporation 10550 Talbert Avenue Los Angeles, California 92708 | |
Re: Hyundai Auto Receivables Trust 2007-A Registration Statement on Form S-3 Registration No. 333-144832 |
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:
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,
Mayer, Brown, Rowe & Maw LLP operates in combination with our associated English limited liability partnership in the offices listed above.
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Hyundai Auto Receivables Trust 2007-A | |
September 19, 2007 | |
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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.
WRL/ADH
Very truly yours,
Mayer Brown LLP
Opinion re Tax Matters (Exhibit 8.1)