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                                                                     EXHIBIT 8.1

                         [BAKER & MCKENZIE LETTERHEAD]

Trenwick Group Inc.                                              August 23, 2000
One Canterbury Green
Stamford, Connecticut 06901

Trenwick Group Ltd.
Continental Building
25 Church St.
Hamilton HM 12
Bermuda

     Re: U.S. Federal Income Tax Consequences of the Acquisition of the Assets
         and the Assumption of the Liabilities of Trenwick Group Inc. by
         Trenwick Group Ltd.

Ladies and Gentlemen:

     We have acted as your counsel, in connection with the acquisition of the
assets and the assumption of the liabilities (the "Reorganization") of Trenwick
Group, Inc., a Delaware corporation ("Trenwick") by Gowin Holdings International
Limited, a newly formed Bermuda holding company which has changed its name to
Trenwick Group Ltd. ("TGL"), pursuant to the Amended and Restated Agreement,
Scheme of Arrangement and Plan of Reorganization by and among LaSalle Re
Holdings Limited, LaSalle Re Limited, Trenwick and TGL dated as of March 20,
2000 and amended as of June 28, 2000 (the "Reorganization Agreement").

     Pursuant to the Reorganization, each share of common stock, $0.10 par value
per share, of Trenwick (the "Trenwick Shares") shall be converted into the right
to receive 1 common share, $0.10 par value per share, of TGL (the "TGL Shares")
subject to adjustment in accordance with Section 2.7 of the Reorganization
Agreement.

     You have requested certain opinions regarding the U.S. federal income tax
treatment of the Reorganization.

     In providing these opinions, we have relied on and assumed the accuracy of
(without any independent investigation or review thereof) (i) the description of
the transaction as set forth in the Reorganization Agreement and the exhibits
thereto, (ii) the description of the transaction as set forth in the joint proxy
statement and prospectus on Schedule 14A (file no. 1-15389) (the "Registration
Statement"), (iii) the representations provided by Trenwick concerning certain
facts underlying and relating to the Reorganization, and (iv) the
representations provided by TGL concerning certain facts underlying and relating
to the Reorganization.

     Based upon and subject to the foregoing, it is our opinion that:

          (i) no gain or loss will be recognized by United States shareholders
     of Trenwick upon the receipt of solely TGL Shares pursuant to the
     Reorganization Agreement (except with respect to cash received in lieu of a
     fractional share interest in TGL shares);

          (ii) the Reorganization will qualify as a tax-free reorganization
     within the meaning of section 368(a) of the Internal Revenue Code of 1986,
     as amended (the "Code");

          (iii) Trenwick will be required to recognize gain, but not loss, with
     respect to each asset it transfers to TGL pursuant to the Reorganization
     under section 367(a) of the Code; and

          (iv) the discussions of the material United States federal income tax
     consequences to Trenwick and its shareholders and to TGL and the
     subsidiaries and the shareholders of TGL set forth in the Proxy Statement
     under the captions "The Transactions -- Material Income Tax Consequences of
     the Transactions -- Taxation of the Transactions -- United States," "The
     Transactions -- Material Income Tax Consequences of the
     Transactions -- Taxation of Trenwick Group Ltd. and Its Subsidiaries after
     the
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     Transactions -- United States," and "The Transactions -- Material Income
     Tax Consequences of the Transactions  -- Taxation of Shareholders of
     Trenwick Group Ltd. -- United States" are complete and accurate in all
     material respects, but are limited by the qualifications set forth in the
     Proxy Statement section captioned "The Transactions -- Material Income Tax
     Consequences of the Transactions."

     This opinion is based on current provisions of the Code, the Treasury
regulations promulgated thereunder, and the interpretation of the Code and such
regulations by the courts and the Internal Revenue Service, as they are in
effect and exist at the date of this opinion. It should be noted that statutes,
regulations, judicial decisions and administrative interpretations are subject
to change at any time and, in some circumstances, with retroactive effect. A
material change that is made after the date hereof in any of the foregoing bases
for our opinion could adversely affect our conclusions.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to all references to this firm under the headings
"The Transaction -- Material Income Tax Consequences of the Transactions" and
"Legal Matters". In giving this consent, this firm does not thereby admit that
it comes within the category of person whose consent is required under Section 7
of the Act or the rules and regulations of the Commission promulgated
thereunder.

                                          Sincerely,

                                          /s/ BAKER & MCKENZIE
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                                               Baker & McKenzie