EXHIBIT 8.2

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February 21, 2007

Xinhua Finance Media Limited
Rooms 3905-3909
Tower 1, Grand Gateway
1 Hongqiao Lu, Shanghai 200030
People's Republic of China


Re:  American Depositary Shares of Xinhua Finance Media Limited (the "Company")


Ladies and Gentlemen:


     In connection with the public offering on the date hereof of 23,076,923
American Depositary Shares ("ADSs"), each of which represents two common shares,
par value $0.001 per share, of the Company pursuant to the registration
statement on Form F-1 under the Securities Act of 1933, as amended (the "Act"),
originally filed by the Company with the Securities and Exchange Commission (the
"Commission") on February 21, 2007, as amended to date (the "Registration
Statement"), you have requested our opinion concerning the statements in the
Registration Statement under the caption "Taxation--United States federal income
taxation."

     The facts, as we understand them, and upon which with your permission we
rely in rendering the opinion herein, are set forth in the Registration
Statement.

     In our capacity as counsel to the Company, we have made such legal and
factual examinations and inquiries, including an examination of originals or
copies certified or otherwise identified to our satisfaction of such documents,
corporate records and other instruments as we have deemed necessary or
appropriate for purposes of this opinion. In our examination, we have assumed
the authenticity of all documents submitted to us as originals, the genuineness
of all signatures thereon, the legal capacity of natural persons executing such
documents and the conformity to authentic original documents of all documents
submitted to us as copies. For the purpose of our opinion, we have not made an
independent investigation, or audit of the facts set forth in the
above-referenced documents.

     We are opining herein as to the effect on the subject transaction only of
the federal income tax laws of the United States and we express no opinion with
respect to the applicability thereto, or the effect thereon, of other federal
laws, the laws of any state or any



other jurisdiction or as to any matters of municipal law or the laws of any
other local agencies within any state.

     Based on such facts and subject to the limitations set forth in the
Registration Statement, the statements of law or legal conclusions in the
Registration Statement under the caption "Taxation--United States federal income
taxation" constitute the opinion of Latham & Watkins LLP as to the material tax
consequences of an investment in the ADSs or common shares.

     No opinion is expressed as to any matter not discussed herein.

     This opinion is rendered to you as of the date of this letter, and we
undertake no obligation to update this opinion subsequent to the date hereof.
This opinion is based on various statutory provisions, regulations promulgated
thereunder and interpretations thereof by the Internal Revenue Service and the
courts having jurisdiction over such matters, all of which are subject to change
either prospectively or retroactively. Also, any variation or difference in the
facts from those set forth in the Registration Statement may affect the
conclusions stated herein.

     This opinion is furnished to you, and is for your use in connection with
the transactions set forth in the Registration Statement. This opinion may not
be relied upon by you for any other purpose. However, this opinion may be relied
upon by persons entitled to rely on it pursuant to applicable provisions of
federal securities law.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name under the caption "Legal
matters" in the prospectus included in the Registration Statement. In giving
such consent, we do not thereby admit that we are within the category of persons
whose consent is required under Section 7 of the Act or the rules or regulations
of the Commission promulgated thereunder.

                                        Very truly yours,

                                        /s/ Latham & Watkins LLP