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EXHIBIT 8.01
[SIDLEY & AUSTIN LETTERHEAD]
November 8, 2000
Campbell & Company, Inc.
Managing Owner of
Campbell Alternative Asset Trust
210 West Pennsylvania Avenue
Towson, Maryland 21204
Re: Pre-Effective Amendment No. 1 to the Registration Statement on Form S-1
Ladies and Gentlemen:
We have acted as your counsel in connection with the preparation and filing
with the Securities and Exchange Commission (the "Commission") under the
Securities Act of 1933, as amended (the "Act"), of the Registration Statement on
Form S-1 on or about May 22, 2000 (the "Registration Statement"), and
Pre-Effective Amendment No. 1 thereto filed with the Commission on or about
November 8, 2000 (the "Amendment") relating to Units of Beneficial Interest of
Campbell Alternative Asset Trust, formerly Campbell Asset Allocation Trust (the
"Trust"), a business trust organized under the Delaware Business Trust Act.
We have reviewed such data, documents, questions of law and fact and other
matters as we have deemed pertinent for the purpose of this opinion. Based upon
the foregoing, we hereby confirm our opinion expressed under the caption
"Federal Income Tax Aspects" in the Prospectus (the "Prospectus") constituting a
part of the Registration Statement and the Amendment that the Trust will be
taxed as a partnership for federal income tax purposes.
We also advise you that in our opinion the description set forth under the
caption "Federal Income Tax Aspects" in the Prospectus correctly describes
(subject to the uncertainties referred to therein) the material aspects of the
federal income tax treatment to an individual taxpayer, as of the date hereof,
of an investment in the Trust.
We hereby consent to the filing of this opinion as an Exhibit to the
Registration Statement and to the Amendment and all references to our firm
included in or made a part of the Registration Statement and the Amendment. In
giving such consent, we do not thereby admit that we are in the category of
persons whose consent is required under Section 7 of the Act or the rules and
regulations of the Commission thereunder.
Very truly yours,
SIDLEY & AUSTIN
