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                                                                    Exhibit 8.1

                  [LETTERHEAD OF MAYER, BROWN, ROWE & MAW LLP]


November 25, 2003

Deutsche Bank Securities Inc.
60 Wall Street, 19th Floor
New York, New York 10005

Merrill Lynch, Pierce, Fenner & Smith
     Incorporated
World Financial Center, North Tower
New York, New York 10281

as Representatives of the Several Underwriters

         Re: CNH Equipment Trust 2003-B
             --------------------------

Ladies and Gentlemen:

         We have acted as special Federal tax counsel for CNH Equipment Trust
2003-B, a Delaware statutory trust (the "TRUST"), in connection with the
issuance and sale of Class A-1 Asset Backed Notes (the "CLASS A-1 NOTES"), Class
A-2 Asset Backed Notes (the "CLASS A-2 NOTES"), Class A-3a Asset Backed Notes
(the "CLASS A-3a NOTES"), Class A-3b Asset Backed Notes (the "CLASS A-3b
NOTES"), Class A-4a Asset Backed Notes (the "CLASS A-4a NOTES"), Class A-4b
Asset Backed Notes (the "CLASS A-4b NOTES") and the Class B Asset Backed Notes
(the "CLASS B NOTES", together with the Class A-1 Notes, the Class A-2 Notes,
the Class A-3a Notes, the Class A-3b Notes, the Class A-4a Notes and the Class
A-4b Notes, the "NOTES"), to be issued pursuant to the Indenture, dated as of
November 1, 2003 (the "INDENTURE"), between the JPMorgan Chase Bank, as
Indenture Trustee. Capitalized terms not otherwise defined herein are used as
defined in the Sale and Servicing Agreement, dated as of November 1, 2003 (the
"SALE AND SERVICING AGREEMENT"), among the Trust, as Issuer, CNH Capital
Receivables Inc. ("CNHCR"), as Seller, and Case Credit Corporation ("CASE
CREDIT"), as the Servicer.

         In that connection, we have examined originals or copies, certified or
otherwise identified to our satisfaction, of such documents, corporate records
and other instruments as we have deemed necessary or appropriate for the
purposes of this opinion, including: (a) the Prospectus, dated November 13, 2003
(the "PROSPECTUS"), and the Prospectus Supplement (to the Prospectus), dated
November 13, 2003 (the "PROSPECTUS SUPPLEMENT"), relating to the Notes, as filed
with the Securities and Exchange Commission pursuant to the Securities Act of
1933, as amended, (b) the NH Purchase Agreement, dated as of

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November 25, 2003
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November 1, 2003, between New Holland Credit Company, LLC and CNHCR, (c) the
Case Purchase Agreement, dated as of November 1 2003, between Case Credit and
CNHCR, (d) the Sale and Servicing Agreement, (e) the Trust Agreement, dated
as of November 1, 2003, (the "Trust Agreement"), between CNHCR, as Depositor,
and The Bank of New York, as trustee (the "Trustee"), (f) the Indenture and
(g) specimens of the Notes.

         The opinion set forth in this letter is based on reasoning from legal
principles based on the relevant provisions of the Internal Revenue Code of
1986, as amended, the legislative history thereof, currently applicable Treasury
regulations, judicial decisions, administrative rulings and such other
authorities as we have considered relevant. There can be no assurance that the
opinions expressed below could not be successfully challenged by the Internal
Revenue Service, or significantly altered by legislative changes, changes in
administrative positions or judicial decisions, any of which may be applied
retroactively with respect to the completed transactions. Any such change could
render the affected provisions of this opinion inoperative. No tax rulings will
be sought from the IRS with respect to any of the matters discussed herein.

         Based upon the foregoing, we hereby confirm that: (i) the statements
set forth in the Prospectus under the heading "U.S. Federal Income Tax
Consequences" and in the Prospectus Supplement under the heading "Summary of
Terms--Tax Status" (to the extent relating to Federal income tax consequences)
accurately reflect our opinion; (ii) the statements set forth in the Prospectus
under the heading "Illinois State Tax Consequences" and in the Prospectus
Supplement under the heading "Summary of Terms--Tax Status" (to the extent
relating to Illinois state income tax consequences) accurately reflect our
opinion; and (iii) the statements set forth in the Prospectus under the heading
"ERISA Considerations" and in the Prospectus Supplement under the headings
"ERISA Considerations" and "Summary of Terms--ERISA Considerations" accurately
reflect our opinion.

                                                Very truly yours,


                                                /S/ MAYER, BROWN, ROWE & MAW LLP