Exhibit 8.1
[Shearman & Sterling Letterhead]








                                                              October 25, 1999




Ford Motor Credit Company
The American Road
Dearborn, MI 48121


Ladies and Gentlemen:

                  In connection  with the issuance by Ford Motor Credit Company,
a Delaware  corporation,  of $5,000,000,000  aggregate principal amount of its 7
3/8% Global  Landmark  Securities due October 28, 2009, 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 -- Income and Withholding
Tax"  in  the  Prospectus   Supplement   dated  October  21,  1999  relating  to
registration  statement no.  333-75177,  to which  registration  statement  this
consent is an exhibit.


                                                     Very truly yours,


                                                     /s/ Shearman & Sterling