Exhibit 8
                                 PIPER & MARBURY
                                     L.L.P.
                              CHARLES CENTER SOUTH
                             36 SOUTH CHARLES STREET
                         BALTIMORE, MARYLAND 21201-3018
                                  410-539-2530                   WASHINGTON
                                FAX: 410-539-0489                 NEW YORK
                                                                PHILADELPHIA
                                                                   EASTON
                                                                   LONDON
                                February 6, 1996


USF&G Corporation
100 Light Street
Baltimore, Maryland 21201

USF&G Capital I
c/o USF&G Corporation
100 Light Street
Baltimore, Maryland 21201

Ladies and Gentlemen:

         We have  acted as your  special  tax  counsel in  connection  with your
Registration  Statement on Form S-3 under the Securities Act of 1933, as amended
(collectively, the "Registration Statement"), filed with Securities and Exchange
Commission,  with respect to the public offering of Cumulative  Quarterly Income
Preferred  Securities of USF&G I and USF&G Capital II, each a Delaware  business
trust,  and  the  related  Guarantees  and  Deferrable   Interest   Subordinated
Debentures of USF&G Corporation thereunder (the "Preferred Securities").

         We  hereby  confirm,  based  on  the  assumptions  and  subject  to the
qualifications  and  limitations  set forth therein,  that the statements in the
section of the Registration Statement captioned "United States Taxation," to the
extent that such statements  constitute  statements of law, reflect our opinion,
as of the date hereof,  with respect to the matters set forth therein  regarding
federal income tax consequences of the purchase,  ownership,  and disposition of
the  Preferred  Securities.  No opinion is expressed on matters other than those
specifically referred to herein.

         We hereby  consent to the  filing of this  opinion as an exhibit to the
Registration  Statement.  In giving this consent, we do not hereby admit that we
are in the category of persons whose consent is required  under Section 7 of the
Securities Act.

                                        Very truly yours,

                                        /s/ Piper & Marbury L.L.P.