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EXHIBIT 8.2
August 18, 2000
ORIX Credit Alliance Receivables Trust 2000-B
c/o The Bank of New York (Delaware)
502 White Clay Center
Newark DE 19714-6973
ORIX Credit Alliance Receivables 2000-B Corporation
300 Lighting Way
Secaucus NJ 07096-1525
Orix Credit Alliance, Inc.
300 Lighting Way
Secaucus NJ 07096-1525
Gentlemen:
Reference is made to that certain Securities and Exchange Commission Form
S-1 Registration Statement Number 333-43312 (the "Registration Statement"). We
are special New Jersey tax counsel to ORIX Credit Alliance Receivables Trust
2000-B, a Delaware business trust.
As special counsel, we have examined such records, certificates and other
documents, and such questions of law, as we have considered necessary or
appropriate for the purposes of the opinion. Upon the basis of such examination,
we advise you that, in our opinion, the material New Jersey income tax
consequences of the ownership of the Notes by initial purchasers who are not
otherwise subject to taxation of income in New Jersey areas set forth under the
heading "State and Local Tax Considerations -- New Jersey Tax Considerations"
and "Legal Matters" in the Registration Statement is correct in all material
respects.
We hereby consent to the filing of the opinion regarding such New Jersey
state and local tax consideration as an exhibit to the Registration Statement
and to the reference to us under the heading "State and Local Tax
Considerations--New Jersey Tax Considerations" in the Registration Statement. 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.
/s/ Riker, Danzig, Scherer
Hyland & Perretti LLP
