EXHIBIT (8) Haskell Slaughter & Young, L.L.C. 1200 AmSouth/Harbert Plaza 1901 Sixth Avenue North Birmingham, Alabama 35203 July 18, 1996 HEALTHSOUTH Corporation Two Perimeter Park South Birmingham, Alabama 35243 Gentlemen: You have requested our opinion regarding the discussion of material federal income tax consequences under the captions "SUMMARY OF PROSPECTUS--PROXY STATEMENT-The Merger -- Certain Federal Income Tax Consequences" and "THE MERGER - -- Certain Federal Income Tax Consequences" in the Prospectus-Proxy Statement (the "Prospectus-Proxy Statement") which will be included in the Registration Statement on Form S-4 (the "Registration Statement") filed on the date hereof with the Securities and Exchange Commission (the "Commission") under the Securities Act of 1933, as amended (the "Securities Act"). The Prospectus-Proxy Statement relates to the proposed merger of Empire Acquisition Corporation, a wholly-owned subsidiary of HEALTHSOUTH Corporation, with and into Professional Sports Care Management, Inc. This opinion is delivered in accordance with the requirement of Item 601(b)(8) of Regulation S-K under the Securities Act. In rendering our opinion, we have reviewed the Prospectus-Proxy Statement and such other materials as we have deemed necessary or appropriate as a basis for our opinion. In addition, we have considered the applicable provisions of the Internal Revenue Code of 1986, as amended, Treasury regulations, pertinent judicial authorities, rulings of the Internal Revenue Service and such other authorities as we have considered relevant. Based upon the foregoing, it is our opinion that the statements made under the captions "SUMMARY OF PROSPECTUS-PROXY STATEMENT-The Merger -- Certain Federal Income Tax Consequences" and "THE MERGER -- Certain Federal Income Tax Consequences" in the Prospectus-Proxy Statement, to the extent that they constitute summaries or descriptions of matters of law or legal conclusions, are correct in all material respects. There can be no assurance that contrary positions may not be asserted by the Internal Revenue Service. This opinion is being furnished in connection with the Prospectus-Proxy Statement. You may rely upon and refer to the foregoing opinion in the Prospectus-Proxy Statement. Any variation or difference in the facts from those set forth or assumed either herein or in the Prospectus-Proxy Statement may affect the conclusions stated herein. In accordance with the requirements of Item 601(b)(23) of Regulation S-K under the Securities Act, we hereby consent to the use of our name under the caption "THE MERGER -- Certain Federal Income Tax Consequences" in the Prospectus-Proxy Statement and to the filing of this opinion as an Exhibit to the Registration Statement. Very truly yours, HASKELL SLAUGHTER & YOUNG, L.L.C. By /s/ Ross N. Cohen ----------------------------- Ross N. Cohen