Attached files
file | filename |
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8-K - FORM 8-K - WELLS FARGO & COMPANY/MN | d412126d8k.htm |
EX-5.1 - OPINION OF FAEGRE BAKER DANIELS LLP REGARDING THE NOTES - WELLS FARGO & COMPANY/MN | d412126dex51.htm |
EX-4.1 - FORM OF MEDIUM-TERM NOTES, SERIES K, SECURITIES LINKED TO THE NIKKEI 225 INDEX - WELLS FARGO & COMPANY/MN | d412126dex41.htm |
Exhibit 8.1
September 17, 2012
Wells Fargo & Company,
420 Montgomery Street,
San Francisco, California 94104.
Ladies and Gentlemen:
We have acted as special tax counsel to Wells Fargo & Company, a Delaware corporation (the Company), in connection with the issuance of $1,000,000 aggregate face amount of Medium-Term Notes, Series K, Securities Linked to the Nikkei 225 Index due March 17, 2016 as described in the Companys Pricing Supplement No. 245 dated September 12, 2012 (Pricing Supplement 245) to Product Supplement No. 1 dated May 2, 2012, the Prospectus Supplement dated April 13, 2012, and the Prospectus dated April 13, 2012 contained in the Registration Statement on Form S-3, File No. 333-180728 (the Registration Statement). We hereby confirm our opinion as set forth under the heading Material Tax Consequences in Pricing Supplement 245.
We hereby consent to the reference to us under the heading Material Tax Consequences in Pricing Supplement 245 and to the filing of this opinion as an exhibit to a Current Report on Form 8-K of the Company filed with the Securities and Exchange Commission and thereby incorporated by reference into the Companys Registration Statement. In giving such consent, we do not admit that we are within the category of persons whose consent is required under Section 7 of the Securities Act of 1933, as amended.
Very truly yours, |
/s/ Sullivan & Cromwell LLP |