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                                                                     EXHIBIT 8.1


                                [WSGR LETTERHEAD]



                                February 26, 2001



Solectron Corporation
777 Gibraltar Drive
Milpitas, California 95035

       RE:    MERGER AMONG SOLECTRON CORPORATION, A DELAWARE CORPORATION
              ("SOLECTRON"), CENTERS ACQUISITION CORPORATION, A DELAWARE
              CORPORATION ("MERGER SUB"), AND CENTENNIAL TECHNOLOGIES, INC., A
              DELAWARE CORPORATION ("CENTENNIAL")

Ladies and Gentlemen:

       We have acted as counsel to Solectron in connection with the proposed
merger (the "Merger") of Solectron's wholly-owned transitory merger subsidiary,
Merger Sub, with and into Centennial pursuant to an Agreement and Plan of Merger
and Reorganization dated as of January 22, 2001 (the "Merger Agreement"). The
Merger and certain proposed transactions incident thereto are described in the
Registration Statement on Form S-4 (the "Registration Statement") of Solectron
which includes the Proxy Statement/Prospectus of Solectron and Centennial (the
"Proxy Statement/Prospectus"). This opinion is being rendered pursuant to the
requirements of Item 21(a) of Form S-4 under the Securities Act of 1933, as
amended. Unless otherwise indicated, any capitalized terms used herein and not
otherwise defined have the meaning ascribed to them in the Merger Agreement.

       In connection with this opinion, we have examined and are familiar with
the Merger Agreement, the Registration Statement, and such other presently
existing documents, records and matters of law as we have deemed necessary or
appropriate for purposes of our opinion. In addition, we have assumed (i) that
the Merger will be consummated in the manner contemplated by the Proxy
Statement/Prospectus and in accordance with the provisions of the Merger
Agreement, (ii) the truth and accuracy of the representations and warranties
made by Solectron, Centennial and Merger Sub in the Merger Agreement, and (iii)
the truth and accuracy of the certificates of representations to be provided to
us by Solectron, Centennial, and Merger Sub.

       Because this opinion is being delivered prior to the Effective Time of
the Merger, it must be considered prospective and dependent on future events.
There can be no assurance that changes in the law will not take place which
could affect the United States Federal income tax consequences of the Merger or
that contrary positions may not be taken by the Internal Revenue Service.


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Solectron Corporation
February 26, 2001
Page 2

       Based upon and subject to the foregoing, in our opinion, the discussion
contained in the Registration Statement under the caption "Material U.S. Federal
Income Tax Consequences," subject to the limitations and qualifications
described therein, sets forth the material United States Federal income tax
consequences generally applicable to the Merger.

       This opinion is furnished to you solely for use in connection with the
Registration Statement. We hereby consent to the filing of this opinion as an
Exhibit to the Registration Statement. We also consent to the reference to our
firm name wherever appearing in the Registration Statement with respect to the
discussion of the material federal income tax consequences of the Merger,
including the Proxy Statement/Prospectus constituting a part thereof, and any
amendment thereto. In giving this consent, we do not thereby admit that we are
in the category of persons 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, nor do we thereby admit that we
are experts with respect to any part of such Registration Statement within the
meaning of the term "experts" as used in the Securities Act of 1933, as amended,
or the rules and regulations of the Securities and Exchange Commission
thereunder.


                                        Very truly yours,

                                        /s/ WILSON SONSINI GOODRICH & ROSATI,
                                            Professional Corporation

                                        WILSON SONSINI GOODRICH & ROSATI
                                        Professional Corporation