EXHIBIT 8.1

                         [STIKEMAN ELLIOTT LETTERHEAD]


                                                 October 19, 2001

C-MAC Industries Inc.
1010 Sherbrooke Street West
Suite 1610
Montreal, Quebec
H3A 2R7


Ladies and Gentlemen:

        With reference to the Registration Statement on Form S-4 (the
"REGISTRATION STATEMENT") filed by Solectron Corporation, a public company
incorporated under the laws of Delaware ("SOLECTRON"), with the United States
Securities and Exchange Commission (the "SEC") in connection with the
registration under the United States Securities Act of 1933, as amended (the
"ACT"), of its common stock, par value US$0.0001 per share, to be issued in
connection with the transactions contemplated by a Combination Agreement dated
as of August 8, 2001, as amended on September 7, 2001, (the "COMBINATION
AGREEMENT"), by and among, inter alia, Solectron and C-MAC Industries Inc., a
corporation incorporated under the laws of Canada ("C-MAC"), we hereby confirm
that the discussion set forth under the caption "Tax Considerations for C-MAC
Securityholders" in the Registration Statement, insofar as it relates to
Canadian law, describes the material Canadian federal income tax consequences
relevant to the C-MAC shareholders with respect to the acquisition of common
stock of Solectron or exchangeable shares of Solectron Global Services Canada
Inc. upon the transactions contemplated in the Combination Agreement.

        We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name in the Registration Statement
and in the Prospectus included therein. Our consent to such reference does not
constitute a consent under Section 7 of the Act, as in consenting to such
reference we have not certified any part of such Registration Statement or
Prospectus and do not otherwise come within the categories of persons whose
consent is required under Section 7 or under the rules and regulations of the
SEC thereunder.

Yours truly,

/s/ Stikeman Elliott