Simpson Thacher & Bartlett April 2, 2001 Cohen & Steers Total Return Realty Fund, Inc. 757 Third Avenue New York, New York 10017 Ladies and Gentlemen: We have acted as counsel to Cohen & Steers Total Return Realty Fund, Inc., a Maryland corporation (the "Company"), in connection with an Agreement and Plan of Reorganization (the "Agreement"), dated as of March 30, 2001, between the Company and Cohen & Steers Realty Income Fund, Inc. ("Realty Income Fund"), a Maryland corporation, pursuant to which the Company will acquire all of the assets and liabilities of Realty Income Fund in exchange for shares of common stock, $.001 par value, of the Company (the "Shares") and cash in lieu of any fractional Shares, which will then be distributed to the holders of common stock, $.01 par value, of Realty Income Fund We have examined the combined prospectus/proxy statement contained in the Company's Registration Statement on Form N-14, with respect to the Agreement (the "Registration Statement"), filed by the Company with the Securities and Exchange Commission (the "Commission") under the Securities Act of 1933, as amended (the "Act"), substantially in the form in which it is to become effective. We also have examined the originals, or duplicates or certified or conformed copies, of such records, agreements, instruments and other documents and have made such other and further investigations as we have deemed relevant and necessary in connection with the opinions expressed herein. As to questions of fact material to this opinion, we have relied upon certificates of public officials and of officers and representatives of the Company. In such examination, we have assumed the genuineness of all signatures, the legal capacity of natural persons, the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as duplicates or certified or conformed copies, and the authenticity of the originals of such latter documents. Based upon the foregoing, and subject to the qualifications and limitations stated herein, we are of the opinion that when (i) the Agreement has been duly approved by the stockholders of the Company in accordance with the listing rules of the New York Stock Exchange, (ii) appropriate Articles of Transfer with respect to the reorganization contemplated in the Agreement have been accepted for record by the Maryland State Department of Assessments and Taxation, and (iii) the Shares have been issued pursuant to the Agreement and the Articles of Transfer and in the manner described in the Registration Statement, the Shares will be validly issued shares, fully paid and nonassessable, under the laws of the State of Maryland. Insofar as the opinion expressed herein relates to or is dependent upon matters governed by the laws of the State of Maryland, we have relied upon the opinion of Venable, Baetjer and Howard, LLP, dated the date hereof. We are members of the Bar of the State of New York and we do not express any opinion herein concerning any law other than the law of the State of New York and, to the extent set forth herein, the law of the State of Maryland. We hereby consent to the filing of this opinion letter as Exhibit 5 to the Registration Statement and to the use of our name under the caption "Legal Matters" in the Prospectus included in the Registration Statement. Very truly yours, SIMPSON THACHER & BARTLETT