Exhibit 8.1

                [Letterhead of Sidley Austin Brown & Wood LLP]








                                            May 8, 2001



Chrysler Financial Company L.L.C.
27777 Franklin Road
Southfield, Michigan 48034

Re:   Chrysler Financial Company L.L.C.
      Registration Statement on Form S-3


Ladies and Gentlemen:

         We have acted as special federal tax counsel to the trusts referred
to below in connection with the filing by Chrysler Financial Company L.L.C., a
Michigan limited liability company (the "Registrant"), of a Registration
Statement on Form S-3 (such registration statement, together with the exhibits
and any amendments thereto as of the date hereof, the "Registration
Statement") with the Securities and Exchange Commission (the "Commission")
under the Securities Act of 1933, as amended (the "Act") for the registration
under the Act of asset backed notes (the "Notes") and asset backed
certificates (the "Certificates") in an aggregate principal amount of up to
$10,000,000,000. As described in the Registration Statement, the Notes and/or
the Certificates will be issued from time to time in series, with each series
being issued by a trust (each, a "Trust") to be formed by the Registrant
pursuant to a Trust Agreement (each, a "Trust Agreement") among the
Registrant, a wholly-owned subsidiary of the Registrant and an owner trustee.
Each series may include one or more classes of Notes, which will be issued
pursuant to an Indenture between the related Trust and an indenture trustee.
Each series may include one or more classes of Certificates, which will be
issued pursuant to a Trust Agreement.

         We have advised the Registrant with respect to certain federal income
tax consequences of the proposed issuance of the Notes and the Certificates.
This advice is summarized under the headings "Summary -- Tax Status" and
"Certain Federal Income Tax Consequences" in the Prospectus and "Federal
Income Tax Consequences" in the Prospectus Supplements, all a part of the
Registration Statement. Such description does not purport to discuss all
possible federal income tax ramifications of the proposed issuance, but with
respect to those federal income tax consequences that are discussed, in our
opinion, the description is accurate in all material respects.

         We hereby consent to the filing of this letter as an exhibit to the
Registration Statement and to a reference to this firm (as special federal tax
counsel to the Trust) under the heading "Certain Federal Income Tax
Consequences" in the Prospectus forming a part of the Registration Statement,
without implying or admitting that we are "experts" within the meaning of the
Act or the rules and regulations of the Commission issued thereunder, with
respect to any part of the Registration Statement, including this exhibit.


                                             Very truly yours,

                                             Sidley Austin Brown & Wood LLP