SEC Info - Hydro Quebec - ‘18-K/A’ for 12/31/11

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Hydro Quebec – ‘18-K/A’ for 12/31/11 – EX-8.1

On: Tuesday, 6/19/12, at 5:09pm ET · For: 12/31/11 · Accession #: 1104659-12-44530 · File #: 1-07770

  As Of                Filer                Filing    For·On·As Docs:Size              Issuer               Agent

 6/19/12  Hydro Quebec                      18-K/A     12/31/11    7:608K                                   Merrill Corp-MD/FA

Amendment to Annual Report of a Foreign Government or Political Subdivision — Form 18-K
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 18-K/A      Amendment to Annual Report of a Foreign Government  HTML     28K 
                          or Political Subdivision                               
 2: EX-1.1      Terms Agreement Dated June 12, 2012                 HTML    146K 
 3: EX-4.1      Fiscal Agency Agreement, Dated as of June 19, 2012  HTML    210K 
 4: EX-5.1      Opinion and Consent of Miller Thomson LLP, Quebec   HTML     49K 
                          and Canadian Counsel to Hydro Quebec                   
 5: EX-5.2      Consent of Norton Rose Canada LLP, Canadian         HTML     11K 
                          Counsel to the Underwriters                            
 6: EX-8.1      Consent of Sullivan & Cromwell LLP, Special United  HTML     10K 
                          States Tax Counsel to Hydro Quebec                     
 7: EX-99.2     Itemized List of Expenses Incurred or to Be         HTML     12K 
                          Incurred or Borne by or for the Account                
                          of Hydro Quebec

EX-8.1 — Consent of Sullivan & Cromwell LLP, Special United States Tax Counsel to Hydro Quebec

This exhibit is an HTML Document rendered as filed. [ Alternative Formats ]

Exhibit 8.1

[SULLIVAN & CROMWELL LLP LETTERHEAD]

June 19, 2012

Hydro-Québec,

75 René-Levesque Boulevard West,

6th Floor,

Montréal, Québec

Canada H2Z 1A4.

Dear Sirs:

As special United States tax counsel to Hydro-Québec in connection with the sale by Hydro-Québec of its U.S.$1,000,000,000 1.375% Global Notes Series JP due June 19, 2017, guaranteed irrevocably and unconditionally by Québec (the “Notes”), we hereby confirm to you our advice as set forth under the heading “Tax Matters - - United States Taxation” in the Prospectus Supplement dated June 12, 2012 to the Prospectus dated December 29, 2011 relating to the Notes, subject to the limitations noted therein, and we consent to the filing of this letter as an exhibit to the amendment to Form 18-K to be filed by Hydro-Québec.

-2-

By 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 of 1933, as amended, or the rules and regulations of the Securities and Exchange Commission.

Very truly yours,

(signed) Sullivan & Cromwell LLP

Dates Referenced Herein and Documents Incorporated by Reference

This ‘18-K/A’ Filing	Date	Other Filings

	6/19/17
Filed on:	6/19/12
	6/12/12	424B3
For Period End:	12/31/11	18-K, 18-K/A
	12/29/11
		List all Filings

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Filing Submission 0001104659-12-044530 – Alternative Formats (Word / Rich Text, HTML, Plain Text, et al.)