Exhibit 8


                           SOLOMON AND WEINBERG LLP
                               ATTORNEYS AT LAW

                               685 THIRD AVENUE
                           NEW YORK, NEW YORK 10017

                                   --------

                                 212.605.1000
                            FACSIMILE 212.605.0999
                                                       SOLOMON AND WEINBERG
                                                       TWO UNIVERSITY PLAZA
                                                    HACKENSACK, NEW JERSEY 07601
                                                            201.487.6800
                                                      FACSIMILE 201.487.6633
WRITER'S DIRECT DIAL NUMBER:



                                                           May 28, 2004


Reckson Associates Realty Corp.
225 Broadhollow Road
Melville, New York  11747

Ladies and Gentlemen:

     You have requested our opinion concerning certain federal income tax
matters with respect to Reckson Associates Realty Corp. (the "Company") in
connection with the Form S-3 registration statement of the Company and Reckson
Operating Partnership, L.P. (the "Operating Partnership") to be filed by the
Company and the Operating Partnership with the Securities and Exchange
Commission (the "SEC") on or about May 28, 2004 (the "Registration
Statement").

     The opinions expressed below are based, in part, upon various assumptions
and factual representations set forth in the Registration Statement (including
the prospectus relating thereto), in registration statements on Forms S-11 and
S-3 previously filed by the Company with the SEC and in a letter delivered to
us by the Company today (the "Representation Letter"), and upon our review of
such other documents as we have considered necessary or appropriate as a basis
for rendering this opinion. We have not made any independent investigation of
the facts set forth in any of these documents. We are not, however, aware of
any material facts or circumstances contrary to or inconsistent with the
representations we have relied upon as described herein or other assumptions
set forth herein. We have assumed that all representations made in the
Representation Letter to the best of the knowledge of any person are true,
correct and complete as if made without such qualification. This opinion is
also based upon the Internal Revenue Code of 1986, as amended (the "Code"),
the Treasury Regulations promulgated thereunder (including temporary and
proposed regulations) and existing administrative and judicial interpretations
thereof (including private letter rulings issued by the Internal Revenue
Service (the "IRS"), which are not binding on the IRS except with respect to a
taxpayer receiving such a ruling), all as they exist at the date of this
letter. All of the foregoing statutes, regulations and interpretations are
subject to change, in some circumstances with retroactive effect. Any changes
to the foregoing authorities might result in modifications of our opinions
contained herein.






     Based on the foregoing, we are of the opinion that, commencing with the
Company's taxable year ended December 31, 2000, the Company has been organized
and operated in conformity with the requirements for qualification and
taxation as a real estate investment trust (a "REIT") under the Code and the
proposed method of operation of the Company will enable the Company to
continue to meet the requirements for qualification and taxation as a REIT
under the Code.

     We express no opinion with respect to the transactions described herein
or in the Registration Statement other than those opinions expressly set forth
herein. Furthermore, the Company's qualification as a REIT will depend upon
the Company's meeting, in its actual operations, the applicable asset
composition, source of income, shareholder diversification, distribution and
other requirements of the Code and Treasury Regulations necessary for a
corporation to qualify as a REIT. We will not review these operations and no
assurance can be given that the actual operations of the Company and its
affiliates will meet these requirements or the representations made to us with
respect thereto for any taxable year.

     This opinion letter is furnished to you for your use in connection with
the Registration Statement. We hereby consent to the filing of this opinion as
Exhibit 8.1 to the Registration Statement and to the use of our name in
connection with the material discussed therein under the caption "Material
Federal Income Tax Consequences," including its use under the caption "Legal
Matters" with respect to such material.

                                 Very truly yours,


                                 /s/ Solomon and Weinberg LLP