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                                                                    Exhibit 8.3

                         [LETTERHEAD OF CONYERS DILL & PEARMAN]

                                                              September   , 1997

Intelligent Polymers Limited
Clarendon House
2 Church Street
Hamilton
Bermuda

Dear Sirs:

     We have acted as Bermuda counsel for Intelligent Polymers Limited
("Intelligent Polymers"), a Bermuda exempted company, in connection with the
proposed issue and sale of up to      units ("Units"), each Unit consisting of
one share of common stock of Intelligent Polymers and one warrant to purchase
one common share of Biovail Corporation International ("Biovail").

     In our capacity as Bermuda counsel to Intelligent Polymers, we
participated in the preparation of the registration statement ("Registration
Statement") on Form F-1/F3 registration nos.      and with respect to the Units
which was filed with the Securities and Exchange Commission ("Commission")
under the Securities Act of 1933 as amended ("Act") of the United States of
America together with all exhibits to the Registration Statement and the forms
of prospectus (the "Prospectus") also filed with the Commission together with
all amendments thereto duly filed in accordance with the Act.

     For the purposes of giving this opinion, we have examined and relied upon
the Registration Statement.  We have also reviewed a copy of the memorandum of
association and bye-laws of Intelligent Polymers certified as a true copy
thereof by the secretary of Intelligent Polymers on September   , 1997, minutes
of meetings of Intelligent Polymers's board of directors and minutes of
shareholders' meetings and such other documents and made such enquiries as to
questions of law as we have deemed necessary in order to render the opinion set
forth below:

We have assumed:


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(i)   the genuineness and authenticity of all signatures and the
      conformity to the originals of all copies (whether or not
      certified) of all documents examined by us and the authenticity
      and completeness of the originals from which such copies were
      taken;

(ii)  the correctness, accuracy and completeness of all factual
      representations made in the Registration Statement and in the
      other documents which we have reviewed; and

(iii) that there is no provision of the law of any jurisdiction, other
      than Bermuda, which would have any implication in relation to the
      opinions expressed herein.

     We have made no investigation of and express no opinion in relation to the
laws of any jurisdiction other than Bermuda.  This opinion is to be governed by
and construed in accordance with the laws of Bermuda and is limited to and is
given on the basis of the current law and practice in Bermuda.

     The term "non assessibility" is not a legal concept under Bermuda law, but
when we describe shares as being "non assessable" (see paragraph 2 below) we
mean with respect to the shareholders of a company, in relation to fully paid
shares of the company and subject to any contrary provision in any agreement in
writing between the company and any one of its shareholders holding such shares
but only with respect to such shareholder, that such shareholder shall not be
bound by an alteration to the memorandum of association or the bye-laws of that
company after the date upon which they became such shareholders, if and insofar
as the alteration requires them to take, or subscribe for additional shares, or
in any way increases their liability to contribute to the share capital of, or
otherwise pay money to, such company.

     On the basis of and subject to the foregoing, we are of the opinion that:

   1. Intelligent Polymers has been duly incorporated and is an existing limited
liability exempted company under the laws of Bermuda, with corporate power and
corporate authority to own, lease and operate its properties and conduct its
business as described in the Prospectus.

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    2. The Common Shares to be sold by Intelligent Polymers as a component of
the Units have been duly authorised, legally issued and, when duly paid for,
will be fully paid and non-assessable; such Intelligent Polymers Common Shares
are not subject to the pre-emptive rights of any shareholder of Intelligent
Polymers; all corporate action required to be taken for the authorization,
issue and the sale of the Intelligent Polymers Common Shares has been validly
taken and on personal liability will attach to holder thereof solely by reason
of the ownership thereof.

    3. The statements in the Registration Statement and Prospectus under the
caption "Taxation-Bermuda Tax Considerations" have been prepared and reviewed
by us and are correct in all material respects.

    4. We hereby consent to the filing of this opinion with the Commission and
as an exhibit to the Registration Statement and Prospectus and to the reference
to this Firm under the captions "Enforceability of Civil Liabilities under
United States Federal Securities Laws", "Taxation-Bermuda Tax Considerations"
and "Legal Matters".

                                            Yours faithfully,


                                            Conyers Dill & Pearman