EXHIBIT 8.1


                                                       FOLEY & LARDNER LLP
                                                       ATTORNEYS AT LAW

                                                       777 EAST WISCONSIN AVENUE
                                      ________, 2005   MILWAUKEE, WI  53202-5306
                                                       414.271.2400 TEL
                                                       414.297.4900 FAX
                                                       www.foley.com

                                                       CLIENT/MATTER NUMBER
                                                       055573-0101

Currency Group LLC,
  d/b/a Rydex Investments
9601 Blackwell Road
Suite 500
Rockville, MD 20850

            Re:      Euro Currency Trust

Ladies and Gentlemen:

         We have acted as legal counsel to Currency Group LLC, a Delaware
limited liability company d/b/a Rydex Investments (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 of the Securities and
Exchange Commission (the "SEC") promulgated thereunder, of a registration
statement on Form S-1, Registration No. 333-125581, initially filed on June 7,
2005, as amended through the date hereof (the "Registration Statement"). The
Registration Statement relates to the proposed issuance by the Euro Currency
Trust (the "Trust"), an investment trust formed on ____________, 2005 under the
laws of the state of New York pursuant to the terms of the Trust Agreement dated
___________, 2005 (the "Trust Agreement") between the Company, as sponsor, and
The Bank of New York, a banking corporation organized under the laws of the
State of New York, as trustee (the "Trustee"), of 150,000 shares, representing
units of fractional undivided beneficial interest in and ownership of the Trust
(the "Shares"). In connection with the issuance of the Shares, you have
requested our opinion with respect to certain U.S. federal tax matters.
Capitalized terms not otherwise defined herein shall have the meanings given to
them in the Trust Agreement.

         In rendering the opinion expressed below, we have examined and relied
on the Registration Statement and originals or copies, certified or otherwise
identified to our satisfaction, of the Trust Agreement and all such other
documents as we have deemed necessary or appropriate in order to enable us to
render the opinion expressed below.

         In our examination of the foregoing documents, we have assumed, with
your consent: that all documents reviewed by us are original documents, or true
and accurate copies of original documents and have not subsequently been
amended; that the signatures on each original document are genuine; that each
party who executed the document had proper authority and capacity; that all
representations and statements set forth in such documents are true and correct;
and that all obligations imposed by any such documents on the parties thereto
have been or will be performed or satisfied in accordance with their terms.



BOSTON       JACKSONVILLE    NEW YORK       SAN DIEGO/DEL MAR   TAMPA
BRUSSELS     LOS ANGELES     ORLANDO        SAN FRANCISCO       TOKYO
CHICAGO      MADISON         SACRAMENTO     SILICON VALLEY      WASHINGTON, D.C.
DETROIT      MILWAUKEE       SAN DIEGO      TALLAHASSEE         WEST PALM BEACH


[FOLEY LOGO OMITTED]
Currency Group LLC
_______________________
________, 2005
Page 2


         Our opinion is based upon the Internal Revenue Code of 1986, as
amended, the Treasury Regulations promulgated thereunder, judicial decisions,
current rulings and pronouncements of the Internal Revenue Service (the "IRS"),
and such other authorities as we have considered relevant, in effect as of the
date of this letter, all of which are subject to legislative, judicial or
administrative change or differing interpretation, possibly with retroactive
effect. Our opinion is not binding on the IRS, and no assurance can be given
that the conclusions expressed herein will not be challenged by the IRS or
sustained by a court.

         Based upon and subject to the foregoing, we confirm that the discussion
in the Registration Statement under the caption "United States Federal Tax
Consequences," to the extent it consists of statement of law and legal
conclusions, and subject to the limitations and qualifications set forth
therein, constitutes our opinion as to the material U.S. federal tax
consequences that apply under currently applicable law to the purchase,
ownership and disposition of the Shares.

         The opinion referred to above represents our best legal judgment as to
the application of the U.S. federal tax laws existing as of the date of this
letter. Further, the opinion referred to above is based upon the assumptions,
documents, facts and representations referred to above. Any material amendments
to such documents, changes in any significant facts or inaccuracy of such
assumptions or representations could affect the accuracy of our opinion.
Although we have made such inquiries and performed such investigations as we
have deemed necessary to fulfill our professional responsibilities as counsel,
we have not undertaken an independent investigation of all the relevant facts.
Our opinion is based solely upon the law and the facts as they exist on the date
hereof; and we disclaim any obligation to advise you of any subsequent change in
law or facts or circumstances that might subsequently come to our attention.

         We hereby consent to the filing of this opinion letter as an exhibit to
the Registration Statement and to the use of our name where it appears in the
Registration Statement. In giving this consent, we do not admit that we are
within the category of persons whose consent is required by Section 7 of the Act
or the rules and regulations of the SEC promulgated thereunder. This opinion
letter may be relied upon by you only in connection with the issuance and sale
of the Shares pursuant to the Registration Statement and may not be relied upon
by you for any other purpose, nor may it be relied upon by any other person for
any purpose, without our prior written consent in each instance.

                                                      Very truly yours,

                                                      FOLEY & LARDNER LLP


                                                      By: _____________________
                                                               Jamshed Patel