EX-8.1 4 dex81.htm OPINION OF SIDLEY AUSTIN LLP AS TO INCOME TAX MATTERS Opinion of Sidley Austin LLP as to income tax matters

Exhibit 8.1

 

 

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SIDLEY AUSTIN LLP

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NEW YORK, NY 10019

(212) 839 5300

(212) 839 5599 FAX

  

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        FOUNDED 1866      

June 19, 2006

DB Commodity Services LLC,

    as Managing Owner of DB Currency Index Value

    Fund and DB Currency Index Value Master Fund

c/o DB Commodity Services LLC

60 Wall Street

New York, New York 10005

 

  Re: DB Currency Index Value Fund and

DB Currency Index Value Master Fund

Pre-Effective Amendment No. 2 to the Registration Statement on Form S-1

Dear Sir or Madam:

We have acted as your counsel in connection with the preparation and filing with the Securities and Exchange Commission (the “SEC”) under the Securities Act of 1933, as amended, of the Pre-Effective Amendment No. 2 to the Registration Statement on Form S-1, to be filed with the SEC on or about June 19, 2006 (the “Registration Statement”), of DB Currency Index Value Fund (the “Fund”) and DB Currency Index Value Master Fund (the “Master Fund”), each a Delaware statutory trust organized on April 12, 2006.

We have reviewed such documents, questions of law and fact and other matters as we have deemed pertinent for the purpose of this opinion. Based upon the foregoing, we hereby confirm our opinions contained under the heading “Material U.S. Federal Income Tax Considerations” in the Prospectus (the “Prospectus”) constituting a part of the Registration Statement that the Fund will not be classified as an association taxable as a corporation for federal income tax purposes and that the Master Fund will be classified as a partnership for federal income tax purposes.

We also advise you that the tax discussion under the captions “The Risks You Face”, paragraphs (25), (26) and (27), “Summary – U.S. Federal Income Tax Considerations,” and “Material U.S. Federal Income Tax Considerations” in the Prospectus constituting a part of the Registration Statement correctly describes the material aspects of the federal income tax treatment to a United States individual taxpayer, as of the date hereof, of an investment in the Fund and Master Fund.


LOGO    June 19, 2006         
  

 

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   NEW YORK

Our opinion represents our best legal judgment with respect to the proper federal income tax treatment of the Fund, Master Fund and United States individual taxpayers investing in the Fund, based on the materials reviewed. Our opinion assumes the accuracy of the facts as represented in documents reviewed or as described to us and could be affected if any of the facts as so represented or described are inaccurate.

 

Very truly yours,
/s/ Sidley Austin LLP
Sidley Austin LLP