Attached files
file | filename |
---|---|
8-K - FORM 8-K - WELLS FARGO & COMPANY/MN | d416322d8k.htm |
EX-4.1 - FORM OF MEDIUM-TERM NOTES, SERIES K, BUFFERED JUMP SECURITIES - WELLS FARGO & COMPANY/MN | d416322dex41.htm |
EX-5.1 - OPINION OF FAEGRE BAKER DANIELS LLP REGARDING THE NOTES - WELLS FARGO & COMPANY/MN | d416322dex51.htm |
Exhibit 8.1
September 27, 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 $3,000,000 aggregate face amount of Medium-Term Notes, Series K, Buffered Jump Securities Based on the Performance of Brent Crude Oil Futures due September 25, 2015 as described in the Companys Pricing Supplement No. 247 dated September 24, 2012 (Pricing Supplement 247) to 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 headings Material Tax Consequences and United States Federal Income Tax Considerations in Pricing Supplement 247.
We hereby consent to the reference to us under the headings Material Tax Consequences and United States Federal Income Tax Considerations in Pricing Supplement 247 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