<DOCUMENT>
<TYPE>EX-8.1
<SEQUENCE>3
<FILENAME>tex8_1-2983h.txt
<DESCRIPTION>EX-8.1
<TEXT>
<PAGE>

                                                                     EXHIBIT 8.1



                                  June 11, 2004


CONFIDENTIAL
------------
ATTORNEY/CLIENT WORK PRODUCT
----------------------------


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.

<PAGE>

Kinross Gold Corporation
June 11, 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. With your consent, our opinion is further conditioned upon
the accuracy of the following assumptions: (i) that 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 the Prospectus; (ii) that the Merger will qualify as a merger
under the laws of the State of Washington; (iii) that 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 are accurate
in all respects as of the date hereof and will be accurate in all respects as of
the effective time of the Merger as if made as of the effective time of the
Merger; and (iv) that 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), which impose
certain tax reporting requirements on Kinross and Crown with respect to the
Merger.

     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 that 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" constitutes 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."

<PAGE>

Kinross Gold Corporation
June 11, 2004
Page 3


     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.


                                      Very truly yours,

                                      /s/ PARR WADDOUPS BROWN GEE & LOVELESS

                                      PARR WADDOUPS BROWN GEE & LOVELESS

</TEXT>
</DOCUMENT>
