Exhibit 8.1

                                                       [PERKINS COIE LETTERHEAD]

                                              1211 S.W. Fifth Avenue, Suite 1500
                                                         Portland, OR 97204-3715
                                                             PHONE: 503-727-2000
                                                               FAX: 503-727-2222
                                                             www.perkinscoie.com

February 11, 2003


Teekay Shipping Corporation
TK House
Bayside Executive Park
West Bay Street and Blake Road
P.O. Box AP-59213
Nassau, Commonwealth of the Bahamas

RE:      REGISTRATION STATEMENT ON FORM F-3

Ladies and Gentlemen:

         We have acted as counsel to Teekay Shipping Corporation, a Republic of
The Marshall Islands corporation (the "Company"), in connection with the
issuance and sale (the "Offering") by the Company of 5,000,000 PEPS Units (or up
to 5,750,000 PEPS Units if the underwriters exercise their over-allotment option
in full). The PEPS Units will be issued pursuant to the Company's Registration
Statement, including the Prospectus therein, on Form F-3 (No. 333-102594) filed
by the Company with the United States Securities and Exchange Commission (the
"Commission") under the Securities Act of 1933, as amended (the "Securities
Act"), and declared effective February 4, 2003 (the "Registration Statement").
At your request, we have examined the Company's Prospectus supplement filed by
the Company with the Commission on February 11, 2003 in connection with the
Offering (the "Prospectus Supplement").

         You have requested our opinion regarding the accuracy of the United
States federal income tax matters described in the Prospectus Supplement under
the caption "Tax Consequences - Material United States Federal Income Tax
Consequences."

         In rendering our opinion, we have examined the Registration Statement,
the Prospectus Supplement and such other documents as we have deemed necessary
or appropriate. We have relied upon the truth and accuracy at all relevant times
of (i) the facts, statements and representations contained in the Registration
Statement and Prospectus Supplement and (ii) certain factual representations
made by the Company. We also have assumed, without any independent
investigation, the authenticity of original documents submitted to us, the
conformity to the originals of documents







Teekay Shipping Corporation
February 11, 2003
Page 2


submitted to us as copies, and the due and valid execution and delivery of all
such documents where due execution and delivery are a prerequisite to the
effectiveness thereof.



         Based upon the foregoing and subject to the limitations and
qualifications set forth herein, we are of the opinion that the discussion set
forth in the Prospectus Supplement under the caption "Tax Consequences -
Material United States Federal Income Tax Consequences," to the extent it
constitutes descriptions of legal matters or legal conclusions, is accurate in
all material respects.

         This opinion represents our best judgment regarding the application of
the United States federal income tax laws in effect as of the date hereof,
including the applicable provisions of the Internal Revenue Code of 1986, as
amended (the "Code"), applicable Treasury Regulations, published rulings and
administrative practices of the Internal Revenue Service (the "Service") and
court decisions. Our opinion is not binding on the Service or the courts, and
there is no assurance that the Service will not successfully assert a contrary
position. Furthermore, no assurance can be given that future legislative,
judicial or administrative changes, on either a prospective or retroactive
basis, will not adversely affect the accuracy of the conclusions stated herein.
We undertake no responsibility to advise you of any subsequent changes of the
facts, statements, representations or assumptions herein, or of any new
developments in the application or interpretation of the United States federal
income tax laws. In the event any one of the facts, statements, representations,
or assumptions upon which we have relied to issue this opinion is incorrect, our
opinion might be adversely affected and may not be relied upon.

         This opinion addresses only the matters described above, and does not
address any other United States federal state, local or foreign tax consequences
that may result from the purchase, ownership and disposition of PEPS Units,
purchase contracts, notes and Treasury securities that are or may be the
components of a PEPS Unit, and shares of the Company's common stock acquired
under a purchase contract, or any other transaction undertaken in connection
with the Offering. Furthermore, we express no opinion as to the United States
federal income taxation of the Company under Sections 882, 883 or 887 of the
Code.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name under the captions "Legal
Matters" in the





Teekay Shipping Corporation
February 11, 2003
Page 3


Prospectus Supplement. In giving this consent, we do not thereby admit that we
are in the category of persons whose consent is required under Section 7 of the
Securities Act, nor do we admit that we are experts with respect to any part of
the Registration Statement within the meaning of the term "expert" as used in
the Securities Act.

Very truly yours,


S/PERKINS COIE LLP