Exhibit 8.1

Hunton & Williams LLP

Riverfront Plaza, East Tower
951 East Byrd Street
Richmond, Virginia 23219-4074

Tel       804 • 788 • 8200
Fax      804 • 788 • 8218

	FILE NO: 78081.0000020
April 1, 2015

Summit Hotel Properties, Inc.

12600 Hill Country Boulevard, Suite R-100

Austin, Texas 78738

Summit Hotel Properties, Inc.

Qualification as Real Estate Investment Trust

Ladies and Gentlemen:

We have acted as counsel to Summit Hotel Properties, Inc., a Maryland corporation (the “Company”), in connection with the preparation of a registration statement on Form S-3, filed with the Securities and Exchange Commission on March 31, 2015 (the “Registration Statement”), with respect to the offer and resale, from time to time, of up to 412,174 shares of common stock, par value $0.01 per share, of the Company by the selling stockholders named in the prospectus filed as part of the Registration Statement (the “Prospectus”) or in a supplement to the Prospectus. You have requested our opinion regarding certain U.S. federal income tax matters.

In giving this opinion letter, we have examined the following:

1. the Registration Statement and the Prospectus;

2. the Company’s Articles of Incorporation filed on June 30, 2010 with the Maryland Secretary of State, and the Articles of Amendment and Restatement, as amended and supplemented (the “Amended Articles”);

3. the First Amended and Restated Agreement of Limited Partnership of Summit Hotel OP, LP (the “OP”) and the First Amendment, Second Amendment, Third Amendment and Fourth Amendment thereto (as amended, the “Operating Partnership Agreement”);

4. the Third Amended and Restated Operating Agreement of Summit Hotel Properties, LLC, a South Dakota limited liability company, dated as of July 25, 2005;

5. the Agreement and Plan of Merger, dated as of August 5, 2010, by and between the LLC and the OP; and

ATLANTA  AUSTIN  BANGKOK  BEIJING  BRUSSELS  CHARLOTTE  DALLAS  HOUSTON  LONDON  LOS ANGELES

McLEAN  MIAMI  NEW YORK  NORFOLK  RALEIGH  RICHMOND  SAN FRANCISCO  TOKYO  WASHINGTON

www.hunton.com

Summit Hotel Properties, Inc.

April 1, 2015

Page 2

6. such other documents as we have deemed necessary or appropriate for purposes of this opinion.

In connection with the opinions rendered below, we have assumed, with your consent, that:

1. each of the documents referred to above has been duly authorized, executed, and delivered; is authentic, if an original, or is accurate, if a copy; and has not been amended;

2. during the Company’s and the OP’s taxable year ending December 31, 2015 and future taxable years, the factual representations contained (i) in a certificate, dated the date hereof and executed by a duly appointed officer of the Company (the “REIT Officer’s Certificate”), and (ii) in a certificate, dated the date hereof and executed by a duly appointed officer of the OP (the “OP Officer’s Certificate” and together with the REIT Officer’s Certificate, the “Officer’s Certificates”), will be true for such years;

3. the Company will not make any amendments to its organizational documents or the Operating Partnership Agreement after the date of this opinion that would affect the Company’s qualification as a real estate investment trust (a “REIT”) for any taxable year; and

4. no action will be taken by the Company or the OP after the date hereof that would have the effect of altering the facts upon which the opinions set forth below are based.

In connection with the opinions rendered below, we also have relied upon the correctness of the factual representations contained in the Officer’s Certificates. No facts have come to our attention that would cause us to question the accuracy and completeness of such factual representations. Furthermore, where such factual representations involve terms defined in the Internal Revenue Code of 1986, as amended (the “Code”), the Treasury regulations thereunder (the “Regulations”), published rulings of the Internal Revenue Service (the “Service”), or other relevant authority, we have reviewed with the individuals making such factual representations the relevant provisions of the Code, the applicable Regulations and published administrative interpretations thereof.

Based solely on the documents and assumptions set forth above, the factual representations set forth in the Officer’s Certificates, and the discussion in the Prospectus under the caption “Material Federal Income Tax Considerations” (which is incorporated herein by reference), we are of the opinion that:

Summit Hotel Properties, Inc.

April 1, 2015

Page 3

(a)         the Company qualified to be taxed as a REIT pursuant to sections 856 through 860 of the Code for its taxable years ended December 31, 2011 through December 31, 2014, and the Company’s current and proposed method of operation will enable it to continue to satisfy the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2015 and thereafter; and

(b)         the descriptions of the law and the legal conclusions in the Prospectus under the caption “Material Federal Income Tax Considerations” are correct in all material respects.

We will not review on a continuing basis the Company’s or the OP’s, compliance with the documents or assumptions set forth above, or the factual representations set forth in the Officer’s Certificates. Accordingly, no assurance can be given that the actual results of the Company’s operations for any given taxable year will satisfy the requirements for qualification and taxation as a REIT. Although we have made such inquiries and performed such investigations as we have deemed necessary to fulfill our professional responsibilities as counsel, we have not undertaken an independent investigation of all of the facts referred to in this letter or the Officer’s Certificates.

The foregoing opinions are based on current provisions of the Code, the Regulations, published administrative interpretations thereof, and published court decisions. The Service has not issued Regulations or administrative interpretations with respect to various provisions of the Code relating to REIT qualification. No assurance can be given that the law will not change in a way that will prevent the Company from qualifying as a REIT.

The foregoing opinions are limited to the U.S. federal income tax matters addressed herein, and no other opinions are rendered with respect to other U.S. federal tax matters or to any issues arising under the tax laws of any other country, or any state or locality. Additional issues may exist that could affect the federal tax treatment of the transaction that is the subject of the opinion, and this opinion letter does not consider or provide a conclusion with respect to any such additional issues. We undertake no obligation to update the opinions expressed herein after the date of this letter.

This opinion letter speaks only as of the date hereof. Except as provided in the next paragraph, this opinion letter may not be distributed, quoted in whole or in part or otherwise reproduced in any document, or filed with any governmental agency without our express written consent.

Summit Hotel Properties, Inc.

April 1, 2015

Page 4

We hereby consent to the filing of this opinion as an exhibit to the Registration Statement. We also consent to the references to Hunton & Williams LLP under the captions “Material Federal Income Tax Considerations” and “Legal Matters” in the Prospectus. In giving consent, we do not admit that we are in the category of persons whose consent is required by Section 7 of the Securities Act of 1933, as amended, or the rules and regulations promulgated thereunder by the Securities and Exchange Commission.

Very truly yours,

/s/ Hunton & Williams LLP