Exhibit 8.1


                [Letterhead of Sidley Austin Brown & Wood LLP]









                                                           January 25, 2002



DaimlerChrysler Services North America LLC
27777 Franklin Road
Southfield, Michigan 48034

Re:      DaimlerChrysler Services North America LLC
         Registration Statement on Form S-3 (Registration No. 333-75942)



Ladies and Gentlemen:


     We have acted as special federal tax counsel to the trusts referred to
below in connection with the filing by DaimlerChrysler Services North America
LLC, a Michigan limited liability company (the "Registrant"), of a
Registration Statement on Form S-3 (Registration No. 333-75942) (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 $15,000,000,000. 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





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