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Exhibit 8
401 9th Street, N.W.
Washington, DC 2004-2128
(202) 585-8000
Fax: (202) 585-8080
____________, 2003
Boston Capital Associates V L.L.C.
General Partner of Boston
Capital Tax Credit Fund V L.P.
One Boston Place
Suite 2100
Boston, MA 02108-4406
Re: Boston Capital Tax Credit Fund V L.P. Series 47 and Series 48
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Gentlemen:
You have requested our opinion with respect to certain matters in
connection with Boston Capital Tax Credit Fund V L.P., a Delaware limited
partnership (the "Partnership").
We have acted as counsel to the Partnership; to Boston Capital Associates
V L.L.C.., a Delaware limited liability company which is the General Partner of
the Partnership (the "General Partner"); and to BCTC V Assignor Corp., the
assignor limited partner of the Partnership (the "Assignor Limited Partner"), in
connection with the registration by the Partnership under the Securities Act of
l933, as amended, of 7,000,000 additional units of beneficial interests in the
Limited Partnership Interest of the Assignor Limited Partner in Series 47and
Series 48 (the "Units").
In this regard, we have reviewed Registration Statement No. 333-______ (
the "Registration Statement") and the Prospectus (the "Prospectus") constituting
a part thereof filed with the Securities and Exchange Commission (the
"Commission").
The Partnership has issued a Limited Partnership Interest to the Assignor
Limited Partner, which will assign Units thereof to certain investors
("Assignees"). Under certain
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limited circumstances described in the Registration Statement, Units may be held
directly by investors as Limited Partners. The Assignees and such Limited
Partners are collectively referred to as "Investors." This opinion is applicable
to Units held under either form of ownership.
We have reviewed the Partnership's Certificate of Limited Partnership (the
"Certificate"), dated as of October 15, 2003 and filed for recording on October
15, 2003n the office of the Secretary of State of Delaware, which formed the
Partnership and admitted the General Partner to the Partnership, and the
Partnership's Agreement of Limited Partnership (the "Partnership Agreement")
dated as of October 15, 2003. The Partnership Agreement restates in full all of
the terms and conditions of the agreement among the General Partner, the Limited
Partners (including the Assignor Limited Partner) and the Assignees.
We have examined and relied upon (i) the audited Balance Sheet of Boston
Capital Associates V L.L.C.., as of October 21, 2003, and the accompanying
report dated October 21, 2003, by Reznick Fedder & Silverman, Certified Public
Accountants, and (ii) the certificate of John P. Manning dated as of October
_________, 2003, to the effect that there has been no material adverse change in
such financial statements since the respective dates thereof.
In addition, we assume that (i) the Partnership Agreement and any
amendments thereto as may be necessary to reflect the sale and issuance of the
Units will be duly and properly executed in the form reviewed by us, (ii) the
Partnership is operating, and will continue to operate, in accordance with the
terms and conditions of the Certificate and the Partnership Agreement, and (iii)
any creditor who makes any nonrecourse loan to the Partnership will not have or
acquire at any time, as a result of making such loan, any direct or indirect
interest in the profits, capital or property of the Partnership other than as a
creditor.
We have examined the Delaware Revised Uniform Limited Partnership Act, the
relevant provisions of the Internal Revenue Code of l986, as amended, the
applicable Treasury Regulations and other administrative and judicial
interpretations thereof, and such other federal laws, regulations, documents and
records as we have deemed necessary or appropriate in order to render this
opinion.
Based solely on the foregoing, it is our opinion that:
(1) the Partnership is a duly formed and validly existing limited
partnership under the Revised Uniform Limited Partnership Act as in effect
in the State of Delaware;
(2) each Investor's payment for Units will be treated as a direct
capital contribution to the Partnership in exchange for his Units;
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(3) the Partnership will be classified as a partnership for
federal income tax purposes, and the interest of each Investor in the
Partnership will be treated as a partnership interest for federal income
tax purposes; and
(4) the statements and opinions in the Prospectus under the
caption "Federal Income Tax Matters," insofar as they are statements of
federal income tax law or conclusions with respect to federal income tax
law, are correct in all material respects, based upon existing federal
income tax law and present interpretations thereof. We can give no
assurance that such statements will continue to be correct if existing
federal income tax law, or the interpretation thereof, is changed or
modified hereafter.
The opinions set forth above represent our conclusions as to the
application of the existing laws of Delaware and federal income tax law to the
instant matter, and we can give no assurance that changes in such laws, or in
the interpretation thereof, will not affect the opinions expressed by us.
Moreover, there can be no assurance that contrary positions may not be taken by
the Internal Revenue Service, or that a court considering the issues would not
hold contrary to such opinions. Further, the opinions set forth represent our
conclusions based upon the documents reviewed by us and the facts presented to
us. Any material amendments to such documents or changes in any significant fact
could affect the opinions expressed herein.
Our opinion is further qualified to the extent that the validity of any
provision of any agreement or the rights of partners or Assignees may be subject
to or affected by applicable bankruptcy, insolvency, reorganization, moratorium
or similar laws affecting the rights of creditors generally. Further, we do not
express any opinion as to the availability of any equitable or specific remedy
upon any breach of any of the covenants, warranties or other provisions
contained in any of such agreements.
Other than as set forth above, we have not been asked to, and we do not,
render any opinion with respect to the federal income tax treatment of any
specific item of income, gain, loss, deduction or credit of the Partnership.
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We hereby consent to the use of this opinion as an exhibit to the
Registration Statement and to the reference to this firm in the Registration
Statement under the caption "Experts."
Very truly yours,
NIXON PEABODY LLP