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                                                                       EXHIBIT 8




                                  May 26, 2000



FleetBoston Financial Corporation
One Federal Street
Boston, Massachusetts  02110

Fleet Capital Trust VI,
Fleet Capital Trust VII,
Fleet Capital Trust VIII,
Fleet Capital Trust IX, and
Fleet Capital Trust X
c/o FleetBoston Financial Corporation
One Federal Street
Boston, Massachusetts 02110

Re:      Registration Statement on Form S-3
         Registration No. 333-36444
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Ladies and Gentlemen:

         We have acted as counsel to FleetBoston Financial Corporation, a Rhode
Island corporation (the "Company"), and each of Fleet Capital Trust VI, Fleet
Capital Trust VII, Fleet Capital Trust VIII, Fleet Capital Trust IX and Fleet
Capital Trust X, statutory business trusts formed under the laws of the State of
Delaware (the "Trusts"), in connection with the above-captioned registration
statement on Form S-3 (the "Registration Statement") filed with the Securities
and Exchange Commission (the "Commission") for the purpose of registering (i)
Preferred Securities representing undivided beneficial interests in the assets
of the Trust and (ii) Junior Subordinated Debentures issued by the Company to
the Trust, in connection with the sale of the Preferred Securities. All
capitalized terms used herein and not otherwise defined shall have the meanings
set forth in the form of Prospectus Supplement for an offering of Preferred
Securities filed as an exhibit to the Registration Statement (the "Form of
Prospectus Supplement").

         We hereby confirm that, although the discussion set forth under the
heading "UNITED STATES FEDERAL INCOME TAXATION" in the form of Prospectus
Supplement does not purport to discuss all possible United States federal income
tax consequences of the purchase, ownership and disposition of Preferred
Securities, in our opinion, such discussion constitutes, in all material
respects, a fair and accurate summary


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FleetBoston Financial Corporation
May 26, 2000
Page 2


of the United States federal income tax consequences of the purchase, ownership
and disposition of Preferred Securities, based upon current law. It is possible
that contrary positions may be taken by the Internal Revenue Service and that a
court may agree with such contrary positions.

         This opinion is furnished to you solely for your benefit in connection
with the filing of the Registration Statement and, except as set forth below, is
not to be used, circulated, quoted or otherwise referred to for any other
purpose or relied upon by any other person for any purpose without our prior
written consent. We hereby consent to the use of our name under the heading
"Legal Matters" in the Form of Prospectus Supplement and the filing of this
opinion with the Commission as Exhibit 8 to the Registration Statement. In
giving this consent, we do not thereby admit that we are within the category of
persons whose consent is required under Section 7 of the Securities Act of 1933,
as amended, or the rules and regulations of the Commission promulgated
thereunder. This opinion is expressed as of the date hereof unless otherwise
expressly stated and applies only to the disclosure under the heading "UNITED
STATES FEDERAL INCOME TAXATION" set forth in the Form of Prospectus Supplement
filed as of the date hereof. We disclaim any undertaking to advise you of any
subsequent changes of the facts stated or assumed herein or any subsequent
changes in applicable law.

                                                     Very truly yours,

                                                     /s/ Edwards & Angell, LLP
                                                     EDWARDS & ANGELL, LLP


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