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EXHIBIT 8.1
SIDLEY AUSTIN llp 787 SEVENTH AVENUE NEW YORK, NY 10019 (212) 839 5300 (212) 839 5599 FAX |
BEIJING BRUSSELS CHICAGO DALLAS FRANKFURT GENEVA HONG KONG LONDON FOUNDED 1866 |
LOS ANGELES NEW YORK SAN FRANCISCO SHANGHAI SINGAPORE SYDNEY TOKYO WASHINGTON, D.C. |
December 18, 2009
Campbell & Company, Inc.
General Partner of Campbell Strategic Allocation Fund, L.P.
2850 Quarry Lake Drive
Baltimore, Maryland 21209
General Partner of Campbell Strategic Allocation Fund, L.P.
2850 Quarry Lake Drive
Baltimore, Maryland 21209
Re: Registration Statement on Form S-1
Dear Sir or Madam:
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 December 18, 2009 (the Registration
Statement), relating to Units of Limited Partnership Interest of Campbell Strategic Allocation
Fund, L.P. (the Fund), a limited partnership organized under the Delaware Revised
Uniform Limited Partnership 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 that the Fund will be treated 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 a United States individual
taxpayer, as of the date hereof, of an investment in the Fund.
We hereby consent to the filing of this opinion as an Exhibit to the Registration Statement and all
references to our firm included in or made a part of the Registration Statement. In giving such
consent, we do not hereby 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,
/s/ Sidley Austin LLP