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Exhibit 8.1
Form of Opinion
JONES, DAY, REAVIS & POGUE
3500 SunTrust Plaza
303 Peachtree Street, NE
Atlanta, Georgia 30308-3242
(404) 521-3939
_________________, 2000
Nextel International, Inc.
10700 Parkridge Blvd.
Suite 600
Reston, Virginia 20191
Re: Exchange Offer for 12 3/4% Senior Serial Notes due 2010
Dear Sirs:
We have acted as counsel to Nextel International, Inc. (the
"Company") in connection with the Registration Statement on Form S-4, to which
this opinion appears as Exhibit 8, which includes the prospectus of the
Company relating to the offer by the Company to exchange (the "Exchange
Offer") the Company's 12 3/4% Senior Serial Notes due 2010 (the "Exchange
Notes") for the Company's outstanding 12 3/4% Senior Serial Notes due 2010
(the "Outstanding Notes" and together with the Exchange Notes, the "Notes").
We hereby confirm that the opinion expressed in "XIV. United States
Federal Tax Considerations" is our opinion.
We hereby consent to the filing with the Securities and Exchange
Commission of this opinion as an exhibit to the registration statement and to
the reference to this firm in the prospectus constituting part of the
registration statement.
Very truly yours,
