EXHIBIT 8.1

                      [Greenberg Traurig, P.A. Letterhead]


                                  July 9, 2003

Equity One, Inc.
1696 Northeast Miami Gardens Drive
North Miami Beach, Florida 33179

     Re: Federal Income Tax Considerations Relating to Equity One, Inc.
         --------------------------------------------------------------

Ladies and Gentlemen:

     We have acted as counsel to Equity One, Inc., a Maryland corporation (the
"Company"), in connection with the registration statement on Form S-3 being
filed by the Company with the Securities and Exchange Commission under the
Securities Act of 1933, as amended, relating to various classes of stock and
other securities (the "Registration Statement") and the prospectus contained
therein (the "Prospectus").

     In rendering our opinion, we have reviewed the Registration Statement and
the Prospectus, and we have assumed that the statements therein are and will
remain true and complete. In addition, we have reviewed the Amended and Restated
Articles of Incorporation of the Company, as amended to the date hereof, and
U.S. federal income tax returns and other financial information relating to the
Company. We have assumed the conformity to the originals of all documents
submitted to us as copies and the authenticity of the originals of all of those
documents. We have assumed that all factual matters in documents submitted to us
and all of the other information furnished to us are true and complete. Further,
we have assumed that representations made by the Company in the certificate to
us of even date herewith regarding the Company's compliance with requirements in
the Internal Revenue Code of 1986, as amended (the "Code"), to be treated as a
real estate investment trust ("REIT") for U.S. federal income tax purposes are
true and complete. Any variation or difference in the facts from those set forth
or assumed herein may affect the conclusions stated herein.

     Based on the foregoing, in reliance thereon and subject thereto, and based
on the Code, the Treasury regulations promulgated thereunder, administrative
pronouncements of the Internal Revenue Service and judicial decisions, all as in
effect on the date hereof, it is our opinion that:

     1. The statements set forth in the Prospectus under the caption "Material
U.S. Federal Income Tax Considerations," insofar as they purport to describe the
matters of law referred to therein, represent the material U.S. federal income
tax considerations relevant to purchasers of stock or securities of the Company.



Equity One, Inc.
July 9, 2003
Page 2

     2. Commencing with its taxable year that began January 1, 1995, the Company
has been organized in conformity with the requirements of the Code for
qualification as a REIT for U.S. federal income tax purposes, and the Company's
method of operation as described in the certificate from the Company to us will
enable the Company to continue to satisfy the requirements to be taxable as a
REIT for U.S. federal income tax purposes.

     The foregoing opinions are limited to the matters expressly set forth, and
no opinion is to be implied or inferred beyond the matters expressly stated.
These opinions speak only as of the date hereof and are based solely on legal
authorities as they currently exist, and we assume no obligation to update or
supplement these opinions.

     These opinions are furnished to you solely for use in connection with the
Registration Statement and the Prospectus. We hereby consent to the filing of
this opinion as an exhibit to the Registration Statement. We also consent to the
references to the name of our firm under the heading "Material U.S. Federal
Income Tax Considerations" in the Registration Statement and Prospectus.

                                               Very truly yours,

                                               /s/ Greenberg Traurig, P.A.

                                               Greenberg Traurig, P.A.