BAKER & DANIELS
                         600 East 96th Street, Suite 600
                           Indianapolis, Indiana 46240
                                 (317) 569-9600
                               FAX (317) 569-4800
                              www.bakerdaniels.com

                                                                       EXHIBIT 8

March 26, 2004

American General Finance Corporation
601 N.W. Second Street
Evansville, Indiana  47708

                  Re:      Medium-Term Notes, Series I,
                           Due Nine Months or More from Date of Issue

Ladies and Gentlemen:

                  We have acted as United States tax counsel for American
General Finance Corporation, an Indiana corporation (the "Company"), in
connection with the issuance and sale by the Company of up to $7,500,000,000
aggregate principal amount of the Company's Medium-Term Notes, Series I, due
nine months or more from date of issue (the "Notes"), pursuant to:

                  (a)      the Company's Registration Statement on Form S-3,
         Registration No. 333-110318 (the "Registration Statement"), and the
         Prospectus constituting a part thereof, dated December 3, 2003,
         relating to the issuance from time to time of up to $7,500,000,000
         aggregate principal amount of debt securities of the Company pursuant
         to Rule 415 promulgated under the Securities Act of 1933 (the "1933
         Act"); and

                  (b)      the Prospectus Supplement, dated March 26, 2004, to
         the above-mentioned Prospectus relating to the Notes and filed with the
         Securities and Exchange Commission (the "Commission") pursuant to Rule
         424 promulgated under the 1933 Act (the Prospectus dated December 3,
         2003, and the Prospectus Supplement dated March 26, 2004, including the
         documents incorporated by reference therein pursuant to Item 12 of Form
         S-3 under the 1933 Act, being hereinafter collectively referred to as
         the "Prospectus").

                                    EXHIBIT 8



American General Finance Corporation  -2-                         March 26, 2004

                  You have requested our opinion regarding certain United States
federal income tax matters in connection with the offering of the Notes. The
terms of the Notes are described in the Prospectus.

                  We are of the opinion that the information set forth in the
Prospectus under the caption "CERTAIN UNITED STATES FEDERAL INCOME TAX
CONSIDERATIONS" is an accurate summary of the United States federal income tax
consequences purported to be described therein, all based on laws, regulations,
rulings and decisions in effect on the date hereof.

                  We consent to the filing of this opinion as an exhibit to the
Registration Statement.

                                    Yours very truly,

                                    /s/ BAKER & DANIELS