<DOCUMENT>
<TYPE>EX-8.1
<SEQUENCE>4
<FILENAME>tex8_1-1365.txt
<DESCRIPTION>EX-8.1
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<PAGE>

                                                                     Exhibit 8.1

                              _______________, 2004



Kinross Gold Corporation

52nd Floor Scotia Plaza
40 King Street West
Toronto, Ontario Canada M5H 3Y2


Crown Resources Corporation
4251 Kipling Street, Suite 390
Wheat Ridge, Colorado 80033


       Re:    Merger of Crown Merger Corporation with and into Crown Resources
              Corporation

Ladies and Gentlemen:

       We have acted as counsel for Kinross Gold Corporation, a corporation
organized in the province of Ontario, Canada ("Kinross") in connection with the
proposed merger (the "Merger") of Crown Merger Corporation ("Crown Merger"), a
Washington corporation and wholly-owned subsidiary of Kinross, with and into
Crown Resources Corporation, a Washington corporation ("Crown"), pursuant to the
terms of the Acquisition Agreement and Agreement and Plan of Merger by and
between Kinross, Crown Merger and Crown dated as of November 20, 2003 (the
"Merger Agreement"). In that connection, you have requested our opinion
regarding the material United States federal income tax consequences of the
Merger. Unless otherwise specified herein, all capitalized terms used in this
opinion have the meaning assigned to them in the Merger Agreement.

       In the Merger, each issued and outstanding share of Crown common stock
will be converted into the right to receive 0.2911 shares of Kinross common
stock. In addition, at the election of the holder of any unexercised warrant to
purchase Crown common stock, the warrant will be exchanged for 0.2911 shares of
Kinross common stock for each share of Crown common stock that would have been
issued on the exercise of the warrant immediately prior to the Effective Time on
a cashless basis. Cash will be paid in lieu of fractional shares of Kinross
common stock.

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Kinross Gold Corporation
__________, 2004
Page 2


       The Merger and the Merger Agreement are more fully described in the
Kinross Registration Statement on Form F-4 (the "Registration Statement")
relating to the registration of shares of Kinross common stock to which this
opinion is an exhibit, which is being filed by Kinross with the Securities and
Exchange Commission pursuant to the Securities Act of 1933, as amended. The
Registration Statement includes the Proxy Statement/Prospectus (the
"Prospectus") of Crown.

       In rendering the opinion expressed below, we have examined and relied
upon the accuracy of the facts, information and representations and the
completeness of the covenants contained in the Merger Agreement, the
Registration Statement and Prospectus and such other documents as we have deemed
relevant and necessary. Our opinion is conditioned, among other things, not only
upon such accuracy and completeness as of the date hereof, but also the
continuing accuracy and completeness thereof as of the effective time of the
Merger. Moreover, we have assumed the absence of any change to any of such
instruments between the date hereof and the effective time of the Merger.

       We have also assumed the authenticity of all documents submitted to us as
originals, the genuineness of all signatures, the legal capacity of all natural
persons and the conformity with original documents of all copies submitted to us
for our examination. We have further assumed that: (i) the transactions related
to the Merger or contemplated by the Merger Agreement will be consummated (A) in
accordance with the Merger Agreement and (B) as described in the Registration
Statement and Prospectus; (ii) the Merger will qualify as a statutory merger
under the laws of the State of Washington; (iii) as of the date hereof, and as
of the effective time of the Merger (as if made as of the effective time of the
Merger), the written statements made by executives of each of Kinross, Crown
Merger and Crown in their respective Tax Representation Letters to us of even
date herewith, will be accurate in all respects; and (iv) Kinross, Crown Merger
and Crown will comply fully with all covenants under the Merger Agreement and
all applicable post-merger reporting requirements under the Internal Revenue
Code of 1986, as amended (the "Code") with respect to the Merger, including
without limitation the special reporting requirements of Treasury Regulation
Section 1.367(a)-3(c)(6).

       In rendering our opinion, we have considered the applicable provisions of
the Code, Treasury Regulations, pertinent judicial authorities, interpretive
rulings of the Internal Revenue Service and such other authorities as we have
considered relevant. It should be noted that the Code, Treasury Regulations and
such judicial precedents, rulings and other authorities are subject to change at
any time and, in some circumstances, with retroactive effect; and any such
changes could affect the opinions stated herein.

       Based upon and subject to the foregoing, the discussion contained in the
Prospectus under the caption "United States Federal Tax Consequences of the
Merger" represents our opinion of the material United States federal income tax
consequences of the Merger.

       We express no opinion on any issue relating to income tax consequences of
the Merger other than those described under the caption "United States Federal
Tax Consequences of the Merger."

       We assume no obligation to update or supplement this letter to reflect
any facts or circumstances which may hereafter come to our attention with
respect to the opinions expressed above, including any changes in applicable law
which may hereafter occur.

       We hereby consent to the filing of this letter as an exhibit to the
Registration Statement and to all references to our firm included in or made
part of such Registration Statement.

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