1
                       [BAKER BOTTS L.L.P. LETTERHEAD]


August 9, 2000

021031.0129



EGL, Inc.
15350 Vickery Drive
Houston, Texas 77032

Ladies and Gentlemen:

         We have acted as your counsel in connection with the transactions
contemplated by the Agreement and Plan of Merger among EGL, Inc. ("EGL"), EGL
Delaware I, Inc. ("Merger Sub") and Circle International Group, Inc. ("Circle"),
dated as of July 2, 2000 (the "Merger Agreement"). Pursuant to the Merger
Agreement, Merger Sub will merge with and into Circle (the "Merger"). In that
connection, we have participated in the preparation of a registration statement
under the Securities Act of 1933, as amended, of EGL on Form S-4 (Registration
No. 333-42310) in the form thereof filed with the Securities and Exchange
Commission (as amended, the "Registration Statement"), including a Joint Proxy
Statement/Prospectus forming Part I of the Registration Statement (the "Proxy
Statement").

         We have examined the Merger Agreement, the Proxy Statement, and the
representation letters of EGL and Circle (the "Representation Letters")
delivered to us for purposes of this opinion, and such other documents and
corporate records as we have deemed necessary or appropriate for purposes of
this opinion. In addition, we have assumed (i) the Merger will be consummated in
the manner contemplated in the Proxy Statement and in accordance with the
provisions of the Merger Agreement, (ii) the statements concerning the Merger
set forth in the Proxy Statement are accurate and complete, and (iii) the
representations made to us in the Representation Letters are accurate and
complete.

         Based upon and subject to the foregoing, it is our opinion that, under
currently applicable law, the Merger will constitute a reorganization within the
meaning of section 368(a) of the Internal Revenue Code of 1986, as amended, and
that, accordingly, the following will be the principal federal income tax
consequences of the Merger:

         (1)  no gain or loss will be recognized by a Circle stockholder on the
              exchange of a Circle common share for an EGL common share pursuant
              to the terms of the Merger,

         (2)  the tax basis of each EGL common share received in the Merger will
              be the same as the basis of the Circle common share surrendered in
              exchange for that share, and


   2

EGL, Inc.



                                       2                          August 9, 2000



         (3)  the holding period of each EGL common share received in the Merger
              will include the period that the Circle common share surrendered
              in exchange therefor was held by the holder, provided the
              surrendered share was held as a capital asset of the holder.

         We hereby consent to the filing of this opinion as Exhibit 8 to the
Registration Statement and to the references to this Firm in the sections
captioned "The Merger -- Material United States Federal Income Tax Consequences
of the Merger" and "Legal Matters" in the Proxy Statement. In giving this
consent, we do not thereby admit that we come within the category of a person
whose consent is required under Section 7 of the Securities Act of 1933, as
amended, or the rules and regulations of the Securities and Exchange Commission
thereunder.

         This opinion relates solely to certain federal income tax consequences
of the Merger and no opinion is expressed as to the tax consequences under any
foreign, state or local tax law or under any federal tax law other than those
pertaining to the income tax.

         We are furnishing this opinion to you solely in connection with the
Merger and this opinion is not to be relied upon, circulated, quoted or
otherwise referred to by other persons for any purpose.

                                         Very truly yours,

                                         BAKER BOTTS L.L.P.





GVN:430