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Exhibit 8.1
September 22, 2000
travelbyus.com ltd.
204-3237 King George Highway
South Surrey, British Columbia
V4P 1B7
Ladies and Gentlemen:
Re: Aviation Group, Inc.
Form S-4 Registration Statement
We are of the opinion that the commentary contained under the heading "Federal
Income Tax Considerations Relating to the Arrangement - Canadian Federal Income
Tax Considerations" contained in the Registration Statement on Form S-4 under
the Securities Act of 1933 filed on or about Septebmer 22, 2000 is a fair and
accurate summary in all material respects of the Canadian Federal income tax
considerations relating to the Arrangement insofar as it relates to statements
of law or legal conclusions.
We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and consent to the use of our name in connection
therewith. In giving such consent, we do not thereby admit that we come within
the category of persons whose consent is required under Section 7 of the
Securities Act or the rules and regulations of the Commission promulgated
thereunder.
This opinion has been delivered to you solely for the purpose of being included
as an exhibit to the Registration Statement. It may not be relied upon for any
other purpose or by any other person or entity, and may not be made available to
any other person or entity without our prior written consent. Our opinion
speaks only as of the date hereof and we disclaim any duty to update such
opinion.
Yours truly,
/s/ Cassels Brock & Blackwell LLP
