1

                                                                     EXHIBIT 8.3

                      [BUREAU FRANCIS LEFEBVRE LETTERHEAD]



                                                              December 6, 2000

Vivendi Universal
42, avenue de Friedland
75380 Paris Cedex 08
France

Ladies and Gentlemen:

      Reference is made to the Post-Effective Amendment No. 1 on Form F-1 to the
Registration Statement (the "Registration Statement") on Form F-4 of Vivendi
Universal (currently named Sofiee), a French societe anonyme ("Vivendi
Universal"), relating to the exchange from time to time of non-voting
exchangeable shares of Vivendi Universal Exchangeco, a Canadian subsidiary of
Vivendi Universal, for ordinary shares of Vivendi Universal, represented by
American depositary shares.

      Our opinion, subject to the limitations and conditions set forth therein,
concerning certain French income tax consequences of holding and disposing of
Vivendi Universal ordinary shares, under currently applicable French income tax
law, is set forth in the discussion under the caption "TAX INFORMATION -- French
Tax Considerations of Holding and Disposing of Vivendi Universal Shares" in the
Registration Statement.

      We hereby consent to the filing of this opinion with the Securities and
Exchange Commission as an exhibit to the Registration Statement, and to the
references therein to us. In giving such consent, we do not thereby admit that
we are in the category of persons whose consent is required under Section 7 of
the Securities Act of 1933, as amended.



                                                Very truly yours,



                                                /s/ Renaud Streichenberger
                                                Renaud Streichenberger