Exhibit 8.1


[Letterhead of Willkie Farr & Gallagher]








June 8, 1998




NEXTLINK Communications, Inc.
155 108th Avenue N.E., 8th Floor
Bellvue, WA 98004




         Re:  $335,000,000 9% Senior Notes due 2008
              Exchange Offer



Ladies and Gentlemen:

         We have acted as counsel for NEXTLINK Communications, Inc., a
Washington corporation, (the "Company"), in connection with the filing by the
Company with the Securities and Exchange Commission (the "Commission") of a
registration statement (the "Registration Statement") on Form S-4 under the
Securities Act of 1933, as amended, relating to the proposed issuance, in
exchange for $335,000,000 aggregate principal amount of the Company's 9% Senior
Notes due 2008 (the "Old Notes"), of $335,000,000 aggregate principal amount of
the Company's 9% Senior Notes due 2008 (the "New Notes"). The New Notes are to
be issued pursuant to an indenture dated as of March 3, 1998 (the "Indenture"),
between the Company and The United States Trust Company, as trustee (the
"Trustee"). Capitalized terms used herein and not otherwise defined herein have
the meanings ascribed thereto in the Indenture.

         We hereby confirm that the statements set forth in the prospectus (the
"Prospectus") forming a part of the Registration Statement under the subheading
"Certain United States Federal Tax Consequences" accurately describe the




material Federal income tax consequences to holders of the New Notes issued
pursuant to the Prospectus.

         We know that we are referred to under the heading "Legal Matters" in
the Prospectus, and we hereby consent to such use of our name therein and to the
use of this opinion for filing with the Registration Statement as Exhibit 8.1
thereto.

Very truly yours,





/s/ Willkie Farr and Gallagher