EXHIBIT 8.1


                          CARTER LEDYARD & MILBURN LLP
                               Counselors at Law

                                 2 Wall Street
                            New York, NY 10005-2072


570 Lexington Avenue                                       1401 Eye Street, N.W.
 New York, NY 10022            Tel (212) 732-3200           Washington, DC 20005
   (212) 371-2720              Fax (212) 732-3232              (202) 898-1515



                                                     November 15, 2004

World Gold Trust Services, LLC
444 Madison Avenue
3rd Floor
New York, NY  10022

                      Re:      streetTRACKS(R) Gold Trust
                               REGISTRATION STATEMENT ON FORM S-1
                               ----------------------------------

Ladies and Gentlemen:

         We have acted as counsel for World Gold Trust Services, LLC, a Delaware
limited liability company (the "Company"), in connection with the preparation
and filing under the Securities Act of 1933, as amended (the "Securities Act"),
and the rules and regulations promulgated thereunder, a registration statement
on Form S-1 (Registration No. 333-105202), as amended by Amendments No. 1, No.
2, No. 3, no. 4 and No. 5 thereto (the "Registration Statement"), including the
prospectus constituting Part I of the Registration Statement (the "Prospectus").
The Registration Statement relates to the proposed issuance by the
streetTRACKS(R) Gold Trust, an investment trust formed on November 12, 2004
under New York law pursuant to a Trust Indenture between the Company as Sponsor
and The Bank of New York as Trustee, of 120,000,000 shares, representing units
of fractional undivided beneficial interest in and ownership of such Trust (the
"Shares").

         We have examined the Prospectus and originals or copies, certified or
otherwise identified to our satisfaction, of all such agreements, certificates
and other statements of corporate officers and other representatives of the
Company, and such other documents, as we have deemed necessary as a basis for
this opinion. In such examination we have assumed the genuineness of all
signatures, the authenticity of all documents submitted to us as originals and
the conformity with the originals of all documents submitted to us as copies. We
have, when relevant facts material to our opinion were not independently
established by us, relied, to the extent we deemed such reliance proper, upon
written or oral statements of officers and other representatives of the Company.

         Based on and subject to the foregoing, we advise you that to the extent
it describes conclusions as to U.S. federal tax law and subject to the
limitations and qualifications described therein, the material under the caption
"United States Federal Tax Consequences" in the Prospectus expresses our opinion
as to the material United States federal income tax consequences that generally
will apply under currently applicable law to the purchase, ownership



World Gold Trust Services, LLC                                              -2-

and disposition of Shares by a "US Shareholder" as defined in the material under
such caption, and as to certain United States federal income, gift and estate
tax consequences that may apply under currently applicable law to an investment
in Shares by a "Non-US Shareholder" as defined in the material under such
caption.

         We consent to the filing of this opinion as an exhibit to the
Registration Statement and to the references to our firm in the material under
the captions "United States Federal Tax Consequences" and "Legal Matters" in the
said Prospectus.

                                                Very truly yours

                                                /s/ Carter Ledyard & Milburn LLP

                                                Carter Ledyard & Milburn LLP

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