EXHIBIT 8


                             Dewey Ballantine LLP
                          1301 Avenue of the Americas
                           New York, New York 10019


                                                                 August 26, 1999


Duke Capital Corporation
526 South Church Street
Charlotte, North Carolina 28202

     Re:  Registration Statement on Form S-3

Dear Sirs:

     We have acted as counsel to Duke Capital Corporation (the "Corporation") in
connection with the preparation of a Registration Statement on Form S-3 (the
"Registration Statement"), including a preliminary prospectus and preliminary
prospectus supplements, which is to be filed with the Securities and Exchange
Commission (the "Commission") for the registration under the Securities Act of
1933 (the "Securities Act"), of (1) Junior Subordinated Notes (the "Junior
Subordinated Notes") to be issued by the Corporation to Duke Capital Financing
Trust IV, Duke Capital Financing Trust V and Duke Capital Financing Trust VI
(the "Trusts"), (2) Trust Preferred Securities (liquidation amount $     per
Preferred Security) to be issued by the Trusts and (3) the Corporation's
Guarantees (as defined in the Registration Statement) with respect to such Trust
Preferred Securities. The Trusts will be organized pursuant to amended and
restated trust agreements between the Corporation and the trustees named
therein. The Junior Subordinated Notes will be issued pursuant to a subordinated
indenture, as supplemented, between the Corporation and the trustee named
therein and the Guarantees will be issued pursuant to guarantee agreements
between the Corporation and the trustee named therein, in each case in the
respective forms filed as exhibits to the Registration Statement.

     On the basis and subject to the accuracy of the statements contained in the
materials referred to above, and our consideration of such other matters as we
have deemed necessary, it is our opinion that under current law the material
federal income tax consequences to holders of Trust Preferred Securities issued
by the Trusts will be as described under the heading "Material Federal Income
Tax Considerations" in the preliminary prospectus supplement relating thereto
constituting part of the Registration Statement. You have not requested, and we
do not express, an opinion concerning any other tax consequences of the issuance
by the Trusts of the Trust Preferred Securities. This opinion is not to be used,
circulated, quoted or otherwise referred to for any purpose without our express
written permission.

                                       1



     We hereby consent to the filing of this opinion with the Commission as an
exhibit to the Registration Statement and to the statements with respect to our
firm in the section captioned "Material Federal Income Tax Considerations" in
the preliminary prospectus supplement relating to the Trust Preferred Securities
constituting part of the Registration Statement. In giving the foregoing
consent, we do not thereby admit that we come within the category of persons
whose consent is required under Section 7 of the Securities Act or the rules and
regulations of the Commission thereunder.

                                        Very truly yours,

                                        /s/ Dewey Ballantine LLP


                                       2