EXHIBIT 8.1


                              July 6, 1999


Bank United Corp.
3200 Southwest Freeway, Suite 1600
Houston, Texas 77027

Ladies and Gentlemen:

We have acted as counsel to Bank United Corp., a Delaware corporation, in
connection with the proposed merger (the "Merger") of BUC Acquisition
Corporation II, a Texas corporation and a direct wholly-owned subsidiary of Bank
United Corp. ("BUC Acquisition"), with and into Texas Central Bancshares, Inc.,
a Texas corporation ("Texas Central"), upon the terms and conditions set forth
in the Agreement and Plan of Reorganization (the "Agreement") dated as of March
23, 1999 by and among Bank United Corp., BUC Acquisition and Texas Central.

You have requested our opinion regarding certain material federal income tax
consequences of the Merger. In rendering our opinion, we have examined and
relied upon the accuracy and completeness of facts, information, covenants, and
representations contained in originals or copies, certified or otherwise
identified to our satisfaction, of the Agreement, the Proxy Statement/Prospectus
filed as part of Registration Statement on Form S-4 (Registration No. 333-81135)
(the "Registration Statement"), and other documents we have deemed necessary and
appropriate. Our opinion is conditioned on, among other things, the accuracy of
the facts, information, covenants and representations set forth in the officer
certificates to be delivered by certain officers of Bank United Corp., BUC
Acquisition and Texas Central upon consummation of the Merger.

Based upon and subject to the foregoing, we hereby confirm that the discussion
set forth in the Proxy Statement/Prospectus filed as part of the Registration
Statement under the caption "Material Federal Income Tax Consequences," as it
relates to the federal income tax consequences of the Merger is our opinion.

We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the references to this firm under the caption
"Legal Opinions" in the Proxy Statement/Prospectus forming a part of the
Registration Statement. In giving this consent,


Bank United Corp.
July 6, 1999
Page 2

we do not admit that we are in the category of persons whose consent is required
under Section 7 of the Securities Act of 1933, as amended.

We express no opinion as to the laws of any jurisdiction other that the federal
laws of the United States of America.



                                    Very truly yours,

                                /s/ BRACEWELL & PATTERSON, L.L.P.
                                    Bracewell & Patterson, L.L.P.