Exhibit 8.1 Phone: 215-569-5500 Fax: 215-569-5555 February 11, 2004 NCO Group, Inc. 507 Prudential Road Horsham, PA 19044 Re: Tax Opinion Agreement and Plan of Merger ---------------------------- Gentlemen: We have acted as counsel to NCO Group, Inc....Nco Group Inc • February 12th, 2004 • Services-consumer credit reporting, collection agencies
We have acted as counsel to NCO Group, Inc. ("Parent") in connection with the merger of NCO Portfolio Management, Inc. ("Company") with and into NCPM Acquisition Corporation ("Purchaser") (the "Merger") pursuant to an Agreement and Plan of Merger dated December 12, 2003 (the "Agreement") by and among (i) Parent, (ii) Company, and (iii) Purchaser. This opinion is being rendered at your request in accordance with ss. 7.2 of the Agreement. All capitalized terms, unless otherwise specified, have the meaning assigned to them in the Agreement.
February 11, 2004 NCO Portfolio Management, Inc. 1705 Whitehead Road Baltimore, MA 21207 Re: Tax Opinion Agreement and Plan of Merger ---------------------------- Gentlemen: We have acted as counsel to NCO Portfolio Management, Inc. ("Company") in...Nco Group Inc • February 12th, 2004 • Services-consumer credit reporting, collection agencies
We have acted as counsel to NCO Portfolio Management, Inc. ("Company") in connection with the merger of Company with and into NCPM Acquisition Corporation ("Purchaser") (the "Merger") pursuant to an Agreement and Plan of Merger dated December 12, 2003 (the "Agreement") by and among (i) NCO Group, Inc. ("Parent"); (ii) Company; and (iii) Purchaser. This opinion is being rendered at your request in accordance with ss. 7.2 of the Agreement. All capitalized terms, unless otherwise specified, have the meaning assigned to them in the Agreement.
