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EXHIBIT 8.1
[Sonnenschein Nath & Rosenthal Letterhead]
December 6, 2000
Garmin Ltd.
Queensgate House
P.O. Box 30464SMB
113 South Church Street, George Town,
Grand Cayman, Cayman Islands
Re: Registration Statement on Form S-1
of Garmin Ltd. (the "Company")
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Ladies and Gentlemen:
We are acting as your United States tax counsel in connection with the
Registration Statement on Form S-1 (the "Registration Statement") to be filed by
the Company with the Securities and Exchange Commission under the Securities Act
of 1933, as amended (the "Act"), for the registration of a maximum of 10,500,000
common shares of the Company, with a par value $0.01 per share (the "Common
Shares").
We have advised the Company in connection with the description of the
material United States federal income tax consequences to holders of Common
Shares of the Company. We explicitly incorporate by reference herein, and adopt
as our opinion, the section of the prospectus forming a part of the Registration
Statement entitled "United States Federal Income Tax Considerations", insofar as
it relates to United States federal income tax matters applicable to holders of
Common Shares discussed therein. Such section does not purport to discuss all
United States income tax consequences that may be relevant to a particular
United States Common Shareholder in light of its particular circumstances.
We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to us in the prospectus forming a
part of the Registration Statement. This consent is not to be construed as an
admission that we are a person whose consent is required to be filed with the
Registration Statement under the provisions of the Act.
Sincerely,
/s/ Sonnenschein Nath & Rosenthal
Sonnenschein Nath & Rosenthal
