EXHIBIT 8.1


                                December 18, 2001

Reinsurance Group of America Incorporated
1370 Timberlake Manor Parkway
Chesterfield, Missouri 63017-6039

     RE:  Reinsurance Group of America Incorporated - Registration Statement on
          Form S-3 with respect to Trust Preferred Income Equity Redeemable
          Securities Units

Ladies and Gentlemen:

         We have acted as special tax counsel to Reinsurance Group of America
Incorporated, a corporation existing under the laws of the State of Missouri
(the "Company"), in connection with the Company's offering of $225,000,000 Trust
Preferred Income Equity Redeemable Securities (PIERS) Units (the "Units"), each
consisting of a preferred security issued by RGA Capital Trust I (the "Trust")
having a stated liquidation amount of $50 and a warrant to purchase shares of
common stock of the Company, pursuant to the Prospectus Supplement dated
December 12, 2001 attached to the Prospectus dated December 3, 2001 (the
"Prospectus Supplement").

         In rendering our opinion, we have examined and relied upon without
independent investigation as to matters of fact the Prospectus Supplement and
such other documents as we have considered relevant for purposes of this
opinion. Our opinion is expressly conditioned on, among other things, the
accuracy and completeness as of the date hereof, and the continuing accuracy, of
all of such facts, information, covenants, statements and representations
included in these documents through and as of the effective date of the
above-described offering. Any material changes in the facts referred to, set
forth or assumed herein or in the documents may affect the conclusions stated
herein. We have assumed the genuineness of all signatures, the legal capacity of
all natural persons, the authenticity of all documents submitted to us as
originals, the conformity to original documents of all documents submitted to us
as certified copies or photocopies and the authenticity of the originals of such
documents.

         In rendering our opinion, we have considered the applicable provisions
of the Internal Revenue Code of 1986, as amended (the "Code"), Treasury
Regulations promulgated thereunder by the Treasury Department (the
"Regulations"), pertinent judicial authorities, rulings of the Internal Revenue
Service and such other authorities as we have considered relevant. It should be
noted that such laws, Code, Regulations, judicial decisions and administrative



Reinsurance Group of America Incorporated
Page 2
December 12, 2001

interpretations are subject to change at any time and, in some circumstances,
with retroactive effect. A material change in any of the authorities upon which
our opinion is based could affect our conclusions herein.

         Based solely upon and subject to the foregoing, and in reliance thereon
and subject to the exceptions, limitations and qualifications stated herein:

         a)       We confirm that the statements set forth under the caption
                  "Material United States Federal Tax Consequences" in the
                  Prospectus Supplement, insofar as such statements constitute
                  matters of law or legal conclusions as qualified therein, are
                  our opinion and that such statements fairly describe the
                  material United States federal tax consequences to the holders
                  of the Units and are true, accurate and complete in all
                  material respects;

         b)       We are of the opinion that the RGA Capital Trust I as
                  described in the Declaration of the RGA Capital Trust I will
                  be classified as a grantor trust for United States federal
                  income tax purposes and not as an association taxable as a
                  corporation;

         c)       We are of the opinion that the debentures as described in the
                  Indenture will be classified for United States federal income
                  tax purposes as indebtedness of RGA.

         Except as expressly set forth above, we express no other opinion. We
consent to the reference to this firm in the Prospectus Supplement under the
caption "Material United States Federal Tax Consequences" and to the filing of
this opinion as an exhibit to the Current Report on Form 8-K. In giving such
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 of 1933 or the rules
and regulations of the Securities and Exchange Commission.

                                                 Very truly yours,



                                                 /s/ Bryan Cave LLP