Exhibit 8.1



                                  July 15, 2002

NMHG Holding Company
650 N.E. Holladay Street
Suite 1600
Portland, Oregon 97232

          Re:  REGISTRATION STATEMENT ON FORM S-4
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Ladies and Gentlemen:

     We have acted as special tax counsel to NMHG Holding Company (the
"Company") in connection with the issuance of $250 million aggregate principal
amount of the Company's 10% Senior Notes, due 2009. We have participated in the
preparation of the Registration Statement on Form S-4 (No. 333-89248) (the
"Registration Statement") relating to the Company's offer to exchange all such
outstanding notes for notes with substantially identical terms that are
registered under the Securities Act of 1933 (the "Notes").

     In connection with our opinion, we have reviewed and are relying upon the
Registration Statement, including the exhibits thereto, the representations
contained in a letter dated today addressed to us from the Company, and such
other documents, records and instruments as we have deemed necessary or
appropriate for purposes of this opinion.

     This opinion is based upon current provisions of the Internal Revenue Code
of 1986, as amended, current Treasury regulations issued thereunder, current
published administrative rulings and procedures of the Internal Revenue Service,
and judicial decisions published to date, all of which are subject to change or
differing interpretation, possibly with retroactive effect.

     Based upon and subject to the foregoing, it is our opinion that the
material federal income tax consequences to non-U.S. holders of the Notes will
be as described under the heading "U.S. Federal Income Tax Consequences to
Non-U.S. Holders" in the Registration Statement, and that the material federal
income tax consequences of the exchange offer to holders of the Notes will be as
described under the Registration Statement heading, "U.S. Federal Income Tax
Consequences of the Exchange." You have not requested, and we do not express, an
opinion concerning any other tax consequences of the issuance of the Notes.

     We consent to the filing of this opinion as Exhibit 8.1 to the Registration
Statement. In giving this consent, we do not admit that we come within the
category of persons whose consent is required under Section 7 of the Securities
Act of 1933 or the rules and regulations of the Securities and Exchange
Commission thereunder.

                                               Very truly yours,

                                               /s/ Jones, Day, Reavis & Pogue