Exhibit 8.1





                 [Letterhead of Sidley Austin Brown & Wood LLP]








                                                              March 24, 2005



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

Re:      DaimlerChrysler Services North America LLC
         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 DaimlerChrysler Services North America
LLC, 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 $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 Supplement, 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,

                                             /s/ Sidley Austin Brown & Wood LLP
                                             Sidley Austin Brown & Wood LLP




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