1 EXHIBIT 8 BOSE McKINNEY & EVANS LLP 135 North Pennsylvania Street Suite 2700 Indianapolis, Indiana 46204 August 25, 2000 Duke-Weeks Realty Corporation 8888 Keystone Crossing, Suite 1200 Indianapolis, Indiana 46240 Gentlemen: We are acting as counsel to Duke-Weeks Realty Corporation, an Indiana corporation (the "Company"), in connection with the registration by the Company of approximately 5 million shares of the Company's Common Stock, par value $.01 per share (the "Common Stock"), to be sold by the Company through its Direct Stock Purchase and Dividend Reinvestment Plan (the "Plan"). The Common Stock is the subject of a Registration Statement, as amended (the "Registration Statement") filed by the Company on Form S-3 under the Securities Act of 1933, as amended. In connection therewith, you have requested our opinion with respect to certain United States Federal income tax matters discussed in the Prospectus which is contained in the Registration Statement (the "Prospectus"). All capitalized terms used herein have their respective meanings as set forth in the Registration Statement unless otherwise stated. In rendering the opinions stated below, we have examined and relied, with your consent, upon the Registration Statement and such other documents, records and instruments as we have deemed necessary in order to enable us to render the opinion referred to in this letter. We have further assumed the accuracy of the statements and descriptions of the Company's historical and intended activities as described in the Registration Statement and the reports incorporated therein by reference. 2 Duke-Weeks Realty Corporation August 25, 2000 Page 2 Based upon and subject to the foregoing, we are of the opinion that the tax consequences to participants in the Plan under the Code will be consistent with the discussion contained in the section entitled "The Plan-Taxes--20. What are the federal income tax consequences of participating in the plan?" in the Registration Statement. The opinions set forth in this letter represent our conclusions as to the application of federal income tax laws existing as of the date of this letter to the transactions described herein. We can give no assurance that legislative enactments, administrative changes or court decisions may not be forthcoming that would modify or supersede our opinion. Moreover, there can be no assurance that positions contrary to our opinion will not be taken by the IRS, or that a court considering the issues would not hold contrary to such opinion. Further, the opinion set forth above represents our conclusion based upon the documents, facts and representations referred to above. Any material amendments to such documents, changes in any significant facts or inaccuracy of such representations could affect the opinions referred to herein. Although we have made such inquiries and performed such investigations as we have deemed necessary to fulfill our professional responsibilities as counsel, we have not undertaken an independent investigation of the facts referred to in this letter. We express no opinion as to any federal income tax issue or other matter except that set forth above. We consent to the filing of this opinion as an exhibit to the Registration Statement Very truly yours, BOSE McKINNEY & EVANS LLP