Nomura America Finance F-3ASR Automatic shelf registration (foreign)

Exhibit 8.1

[Letterhead of Sullivan & Cromwell LLP]

September 30, 2010

Nomura Holdings, Inc.,

9-1, Nihonbashi 1-chome,

Chuo-ku, Tokyo 103-8645,

Japan.

Nomura America Finance, LLC,

2 World Financial Center, Building B,

New York, New York 10281-1198.

Ladies and Gentlemen:

We have acted as your United States federal income tax counsel in connection with the registration statement under the Securities Act of 1933 on Form F-3 (the “Registration Statement”) filed with the Securities and Exchange Commission on the date hereof. We hereby confirm to you that our opinion as to United States federal income tax matters is as set forth under the heading “United States Taxation” in the prospectus (the “Prospectus”) included in the Registration Statement, subject to the limitations set forth therein.

We hereby consent to the filing of this letter as an exhibit to the Registration Statement and to the reference to us under the heading “United States Taxation” 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/ SULLIVAN & CROMWELL LLP