[Date]



Oppenheimer World Bond Fund
Two World Trade Center
New York, New York  10048-0203

Dear Sirs:

We have reviewed the Agreement and Plan of  Reorganization  between  Oppenheimer
International  Bond Fund  (International  Bond) and Oppenheimer  World Bond Fund
(World  Bond) which is  attached as Exhibit B of World Bond Fund's  Registration
Statement  under  the  Securities  Act of 1933  on  Form  N-14  filed  with  the
Securities  and  Exchange   Commission  on  September18,   2000  concerning  the
acquisition by International  Bond of  substantially  all of the assets of World
Bond solely for voting  shares of  beneficial  interest in  International  Bond,
followed  by  the  distribution  of  such  shares  in  exchange  for  all of the
outstanding shares of World Bond.

Section  368(a)(1)(C),  IRC provides that, when determining whether the exchange
is solely for stock,  the  assumption  by  International  Bond of a liability of
World Bond shall be disregarded.

The  management  of World  Bond has  represented  to us that there is no plan or
intention  by  any  shareholder  of  World  Bond  who  owns  5% or  more  of the
outstanding  shares of World Bond and, to the best of their knowledge,  there is
no plan or intention on the part of the remaining  shareholders of World Bond to
redeem,  sell,  exchange,  or otherwise dispose of International  Bond shares to
World Bond, other than in the ordinary course of business.

Management  of each fund has further  represented  to us that, as of the date of
the exchange,  both  International Bond and World Bond will qualify as regulated
investment   companies  or  will  meet  the  diversification   test  of  Section
368(a)(2)(F)(ii),  IRC,  and that a  significant  portion  (as  contemplated  by
Regulation Section 1.368-1(d)(3), IRC) of Oppenheimer World Bond Fund's existing
assets  will  continue  to be  held  beyond  the  date  of the  transaction  and
liquidated only in the ordinary course of business.

In our opinion, the federal tax consequences of the transaction,  if carried out
in the  manner  outlined  in the  Agreement  and in  accordance  with the  above
representations, will be as follows:

1. The  transactions  contemplated  by the Agreement  will qualify as a tax-free
   "reorganization"  within the  meaning of Section  368(a)(1)  of the  Internal
   Revenue  Code of 1986,  as  amended,  and under the  regulations  promulgated
   thereunder.

2. International  Bond and  World  Bond  will  each  qualify  as a  "party  to a
   reorganization" within the meaning of Section 368(b)(2).

3. No gain or loss will be recognized by the shareholders of World Bond upon the
   distribution of shares of beneficial  interest in  International  Bond to the
   shareholders of World Bond pursuant to Section 354.

4. Under  Section  361(a) no gain or loss will be  recognized  by World  Bond by
   reason of the  transfer  of its  assets  solely  in  exchange  for  shares of
   International Bond.

5. Under Section 1032 no gain or loss will be recognized by  International  Bond
   by reason of the transfer of World Bond assets  solely in exchange for shares
   of International Bond.

6. The  stockholders  of World  Bond will  have the same tax  basis and  holding
   period for the shares of beneficial  interest in International Bond that they
   receive  as they had for the stock of World Bond that they  previously  held,
   pursuant to Sections 358(a) and 1223(1), respectively.

7. The securities  transferred by World Bond to International Bond will have the
   same tax basis and holding period in the hands of International  Bond as they
   had for World Bond, pursuant to Sections 362(b) and 1223(1), respectively.

Very truly yours,