Exhibit 8.1

                                  July 24, 2001


Galileo International, Inc.
9700 West Higgins Road, Suite 400
Rosemont, Illinois  60018

Ladies and Gentlemen:

          You have requested our opinion regarding the applicability of Section
368(a) of the Internal Revenue Code of 1986, as amended (the "Code"), to the
statutory merger pursuant to the Delaware General Corporation Law (the "Merger")
of Galaxy Acquisition Corp. ("Purchaser"), a Delaware corporation and wholly
owned subsidiary of Cendant Corporation, a Delaware corporation ("Parent"), with
and into Galileo International, Inc. ("Company"), pursuant to the Agreement and
Plan of Merger dated as of June 15, 2001, by and among Parent, Purchaser, and
Company (the "Merger Agreement").

          This opinion addresses solely the United States federal income tax
matters referred to above. Capitalized terms not otherwise defined herein have
the meanings given them in the Merger Agreement.

          For purposes of rendering this opinion, we have examined such existing
documents and records of Parent, Purchaser, and Company as we have deemed
necessary or appropriate, as well as the Merger Agreement, other documents
relating to the Merger, and the proxy statement/prospectus that Company will
send to its stockholders in connection with a special meeting of stockholders at
which the Merger Agreement will be adopted. With your consent we have also
relied upon the accuracy at all material times of the representations by Parent,
Purchaser, and Company contained in separate tax certification letters dated
July 24, 2001, and have, with your permission, assumed that all such
representations are and will be true at all material times without regard to any
knowledge qualifier that may be set forth therein. We assume that the Merger
Agreement and each of the other documents executed or finalized in connection
with the Merger have not been, and will not be, amended prior to the Effective
Time.

          Based upon the foregoing, we are of the opinion that the Merger will
constitute a reorganization within the meaning of Section 368(a) of the Code.

          Our opinion is based on relevant provisions of the Code and on
administrative interpretations, judicial decisions, and regulations thereunder
or pertaining thereto as in effect on the date of this letter. These authorities
are subject to change, which could be either prospective or retroactive, and we
can provide no assurance as to the effect that any such change may have


Galileo International, Inc.
July 24, 2001
Page2


on the opinion that we have expressed above. We assume no obligation to inform
you of any such change.

          We hereby consent to the discussion of this opinion in the
registration statement, to the filing of this opinion as Exhibit 8.1 to the
registration statement filed by Parent on Form S-4, and to the reference to our
firm under the caption "Legal Matters" in the proxy statement/prospectus
constituting part of that registration statement.


                                 Very truly yours,




                                 Jones, Day, Reavis & Pogue