[O'MELVENY & MYERS LLP LETTERHEAD]

                                                                     EXHIBIT 8.1


October 15, 2003

NILT Trust
Nissan-Infiniti LT
Nissan Auto Leasing LLC II
Nissan Auto Lease Trust 2003-A
990 West 190th Street
Torrance, California 90502

               Re:     NILT Trust
                       Nissan-Infiniti LT
                       Nissan Auto Leasing LLC II
                       Nissan Auto Lease Trust 2003-A
                       Amendment No. 2 to Registration Statement on Form S-1
                       Registration Nos. 333-106763, 333-106763-01,
                                333-106763-02, 333-106763-03

Ladies and Gentlemen:

      We have acted as special counsel to Nissan Auto Leasing LLC II, a Delaware
limited liability company ("NALL II"), NILT Trust, a Delaware statutory trust
("NILT Trust"), Nissan-Infiniti LT, a Delaware statutory trust ("Nissan-Infiniti
LT"), and Nissan Auto Lease Trust 2003-A, a Delaware statutory trust ("NALT
2003-A", or the "Issuer") in connection with the proposed issuance by NALT
2003-A of $1,239,700,000 aggregate principal amount of asset-backed notes (the
"Notes") to be offered pursuant to the above-referenced registration statement
on Form S-1 (such registration statement, as amended, the "Registration
Statement") relating to the Notes. The Registration Statement has been filed
with the Securities and Exchange Commission under the Securities Act of 1933, as
amended (the "1933 Act"), and the rules and regulations promulgated thereunder.

      The Notes will be issued under and pursuant to the indenture between the
Issuer and the Indenture Trustee (as defined in the indenture). The indenture
and the amended and restated trust agreement between NALL II, as transferor, and
Wilmington Trust Company, as owner trustee, in the forms filed with the
Securities and Exchange Commission on October 15, 2003, as exhibits to Amendment
No. 2 to the Registration Statement, are herein referred to as the "Indenture"
and the "Trust Agreement", respectively.


                                        1

      In connection with this opinion letter, we have examined originals or
copies, certified or otherwise identified to our satisfaction, of the
organizational documents of the Issuer, the forms of Indenture and Trust
Agreement included as exhibits to the Registration Statement, the forms of Notes
included as exhibits to such form of Indenture, and such other records,
documents and certificates of the Issuer and other instruments as we have deemed
necessary for the purpose of this opinion. In addition, we have assumed that the
Indenture will be duly authorized, executed and delivered by each of the
respective parties thereto; and that the Notes will be duly authorized, executed
and delivered substantially in the forms contemplated by the Indenture; and that
the Notes will be sold as described in the Registration Statement.

      The law covered by this opinion is limited to the present federal law of
the United States, including relevant provisions of the Internal Revenue Code of
1986, as amended (the "Code"), Treasury Regulations thereunder (including
proposed and temporary Treasury Regulations), and interpretations of the
foregoing as expressed in court decisions, administrative determinations and the
legislative history as of the date hereof. These provisions and interpretations
are subject to change, which may or may not be retroactive in effect, that might
result in modifications of our opinion.

      As special tax counsel to NALL II, NILT Trust, NALT 2003-A, and
Nissan-Infiniti LT, we have advised each of NALL II, NILT Trust, NALT 2003-A,
and Nissan-Infiniti LT with respect to certain federal income tax aspects of the
proposed issuance of the Notes after the date hereof as described in the
Registration Statement. Such advice has formed the basis for the description of
selected federal income tax consequences for holders of the Notes that appears
under the heading "Certain Material Federal Income Tax Consequences" in the form
of prospectus. Such description does not purport to discuss all possible federal
income tax ramifications of the proposed issuance of the Notes, but with respect
to those federal income tax consequences that are discussed, in our opinion, the
description is accurate.

      This opinion is furnished by us as special tax counsel for Nissan-Infiniti
LT, NALT 2003-A, NILT Trust, and NALL II and may be relied upon by you only in
connection with the transactions contemplated by the Indenture or the Trust
Agreement, as applicable. It may not be used or relied upon by you for any other
purpose without our prior written consent. This opinion is expressly limited to
the matters set forth above and we render no opinion, whether by implication or
otherwise, as to any other matters. We assume no obligation to update or
supplement this opinion to reflect any facts or circumstances that may hereafter
come to our attention, or any changes in laws which may hereafter occur.

      We consent to the filing of this letter as an exhibit to the Registration
Statement and to the reference to this firm under the heading "Certain Material
Federal Income Tax Consequences" in the form of prospectus, without admitting
that we are "experts," within the meaning of the 1933 Act or the rules or
regulations of the Securities and Exchange Commission thereunder, with respect
to any part of the Registration Statement, including this exhibit.

                                       Respectfully submitted,

                                       /s/ O'Melveny & Myers LLP


                                        2