Exhibit 8.2

Joe R. Lane (1858-1931) Charles M. Waterman (1847-1924) Richard A. Davidson Michael P. Byrne Theodore F. Olt III Judith L. Herrmann Joseph C. Judge Jason J. O'Rourke Mikkie R. Schiltz Diane E. Puthoff Wendy S. Meyer Ian J. Russell Benjamin J. Patterson Douglas R. Lindstrom, Jr. Abbey C. Furlong Samuel J. Skorepa Kurt P. Spurgeon Joshua J. McIntyre Brett R. Marshall Timothy B. Gulbranson Alexander C. Barnett Eric M. Hartmann Maegan M. Gorham Grace E. Mangieri David C. Waterman Jenny L. Juehring Jessica Y. Kirkpatrick** Samuel P. Cropper   220 North Main Street, Suite 600 Davenport, Iowa 52801-1953 Telephone (563) 324-3246 Fax (563) 324-1616   Writer's Direct Dial: (563) 333-6630 E-Mail Address: bmarshall@l-wlaw.com www.L-WLaw.com   March 2, 2023 Brittany A. Kammerer Sarah T. Oberg Ramirez   Registered Patent Attorney Kathryn E. Cox±*   Of Counsel Thomas N. Kamp* C. Dana Waterman III* James A. Mezvinsky* David A. Dettmann* Terry M. Giebelstein Robert V. P. Waterman, Jr. R. Scott Van Vooren Edmund H. Carroll Diane M. Reinsch* Jeffrey B. Lang Kyle R. Day   Admitted in Iowa and Illinois     * Only Admitted in Iowa **Admitted in California ± Admitted in Florida ±± Only Admitted in Illinois   Illinois Office 3551 7^th Street, Suite 110 Moline, IL  61265

JOHN DEERE CAPITAL CORPORATION	JOHN DEERE RECEIVABLES LLC
P.O. Box 5328	P.O. Box 5328
Madison, WI 53705-0328	Madison, WI 53705-0328
Attention: Manager	Attention: Manager
COMPUTERSHARE DELAWARE	U.S. BANK TRUST COMPANY,
TRUST COMPANY	NATIONAL ASSOCIATION
919 North Market Street, Suite 1600	190 South LaSalle Street, 7th Floor
Wilmington, DE 19801	Mail Code MK-IL-SL7R
	Chicago, IL 60603
MUFG SECURITIES AMERICAS INC.	BOFA SECURITIES, INC.
1221 Avenue of the Americas, 6th Floor	One Bryant Park, 11th Floor
New York, NY 10020	New York, NY 10036
HSBC SECURITIES (USA) INC.	RBC CAPITAL MARKETS, LLC
452 Fifth Avenue	200 Vesey Street
New York, NY 10018	New York, NY 10281
CITIGROUP GLOBAL MARKETS INC.	TD SECURITIES (USA) LLC
388 Greenwich Street	One Vanderbilt Avenue, 11th Floor
New York, NY 10013	New York, NY 10017

RE:	REGISTRATION STATEMENT ON FORM SF-3
	REGISTER JOHN DEERE OWNER TRUST 2023
	(the “Registration Statement”)

 

JOHN DEERE CAPITAL CORPORATION

JOHN DEERE RECEIVABLES LLC

COMPUTERSHARE DELAWARE TRUST COMPANY

U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION

MUFG SECURITIES AMERICAS INC.

BOFA SECURITIES, INC.

HSBC SECURITIES (USA) INC.

RBC CAPITAL MARKETS, LLC

CITIGROUP GLOBAL MARKETS INC.

TD SECURITIES (USA) LLC

March 2, 2023

Page 2

Ladies and Gentlemen:

We have acted as special Iowa tax counsel for John Deere Owner Trust 2023 (the “Trust”) and John Deere Receivables LLC, a Nevada limited liability company (“JDRL”), in connection with the Registration Statement on Form SF-3, as amended (the “Registration Statement”), filed by JDRL on behalf of the Trust with the Securities and Exchange Commission under the Securities Act of 1933, as amended, with respect to the issuance by the Trust of Asset Backed Notes (the “Notes”) and Asset Backed Certificates (the “Certificates”). The Notes are to be issued pursuant to an Indenture dated as of March 2, 2023, between the Trust and U.S. Bank Trust Company, National Association, a national banking association, as indenture trustee, substantially in the form of Exhibits “D”, “E”, “F” and “G” thereto. The Certificates are to be issued substantially in the form of Exhibit “A” to the Trust Agreement dated March 1, 2023, between Computershare Delaware Trust Company, as Owner Trustee, and JDRL, as Depositor. Capitalized terms used but not defined herein shall have the respective meanings ascribed to them in the Underwriting Agreement dated February 22, 2023 among JDRL, John Deere Capital Corporation, MUFG Securities Americas Inc., BofA Securities, Inc., HSBC Securities (USA) Inc., and RBC Capital Markets, LLC, on their own behalf and as representatives of the underwriters named therein.

In connection with this opinion, we have examined originals or copies, certified or otherwise identified to our satisfaction, of (i) the Registration Statement; (ii) the Prospectus included in the Registration Statement; (iii) the Preliminary Prospectus included in the Registration Statement; (iv) the Indenture; (v) the Trust Agreement; (vi) the Sale and Servicing Agreement; (vii) the Administration Agreement; (viii) the Asset Representations Review Agreement; and (ix) the Purchase Agreement (collectively the “Documents”). As to any facts material to the opinion expressed herein, we have relied solely upon the factual matters contained in the representations and statements made in the Documents and we have not independently established or verified their accuracy. We have assumed the genuineness of all signatures, the legal capacity of all natural persons, the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as certified or photostatic copies and the authenticity of the originals of such copies. We have also assumed the due execution and delivery pursuant to due authorization by each of the entities party to the Documents.

We are members of the Bar of the State of Iowa, and we express no opinion as to the laws of any jurisdiction other than the laws of the United States of America and the State of Iowa.

 

JOHN DEERE CAPITAL CORPORATION

JOHN DEERE RECEIVABLES LLC

COMPUTERSHARE DELAWARE TRUST COMPANY

U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION

MUFG SECURITIES AMERICAS INC.

BOFA SECURITIES, INC.

HSBC SECURITIES (USA) INC.

RBC CAPITAL MARKETS, LLC

CITIGROUP GLOBAL MARKETS INC.

TD SECURITIES (USA) LLC

March 2, 2023

Page 3

We hereby confirm that the statements set forth in the Preliminary Prospectus and the Prospectus forming a part of the Registration Statement under the caption “CERTAIN IOWA TAX CONSIDERATIONS” accurately describe the material Iowa income tax consequences to holders of the offered Notes and the Certificates.

We know that we are referred to under the headings “CERTAIN IOWA TAX CONSIDERATIONS” and “LEGAL OPINIONS” in the Preliminary Prospectus and the Prospectus and we hereby consent to the use of our name therein.

Very truly yours,

/s/ Lane & Waterman LLP

LANE & WATERMAN LLP