[SHEARMAN & STERLING LETTERHEAD]                   EXHIBIT 8.1



                                             October 16, 1998




Ford Motor Credit Company
The American Road
Dearborn, Michigan 48121

Ladies and Gentlemen:

     In connection with the issuance by Ford Motor Credit Company, a Delaware
corporation, of $750,000,000 principal amount of its Notes due
October 15, 2001 and $150,000,000 principal amount of its Notes due October
15, 2002, we hereby consent to the use of our name and confirm to
you our tax advice as set forth under the heading "United States Taxation of
Non-United States Persons" in the Prospectus Supplement dated October 16,
1998 relating to registration statement No. 333-50611, to which registration
statement this consent is an exhibit.


                                        Very truly yours,