EXHIBIT 8.1
Campbell & Company, Inc.
General Partner of Campbell Strategic Allocation Fund, L.P.
2850 Quarry Lake Drive
Baltimore,
Maryland 21209
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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 to be filed on or about
April 23, 2010 (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 classified as
a partnership for federal income tax purposes.
We 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.
Sidley
Austin
llp is a limited liability partnership practicing in affiliation with other
Sidley Austin partnerships
