<DOCUMENT>
<TYPE>EX-8.1
<SEQUENCE>6
<FILENAME>h01912exv8w1.txt
<DESCRIPTION>EX-8.1 OPINION OF LATHAM & WATKINS LLP REGARDING CERTAIN U.S. TAX MATTERS
<TEXT>
<PAGE>
                                                                     Exhibit 8.1



(LATHAM & WATKINS LLP LETTERHEAD)

March 3, 2008


Canadian Solar Inc.
199 Lushan Road
Suzhou New District
Suzhou 215129
People's Republic of China



     Re:  $75,000,000 Aggregate Principal Amount of 6.0% Convertible Senior
          Notes due 2017
          -----------------------------------------------------------------


Ladies and Gentlemen:

     In connection with the issuance of $75,000,000 aggregate principal amount
of 6.0% Convertible Senior Notes due 2017 (the "Notes"), convertible into common
shares, without par value, of the Company (the "Common Shares"), under an
indenture dated as of December 10, 2007, in the form most recently filed as an
exhibit to the Registration Statement (as herein defined) between the Company
and The Bank of New York, as trustee, and pursuant to a registration statement
on Form F-3 under the Securities Act of 1933, as amended (the "Act"), filed with
the Securities and Exchange Commission (the "Commission") on March 3, 2008
(the "Registration Statement"), you have requested
our opinion concerning the statements in the Registration Statement under the
caption "Taxation-Certain U.S. Federal Income Tax Considerations."

     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 and the Company's responses to our examinations and inquiries.

     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.

<PAGE>
MARCH 3, 2008
PAGE 2



(LATHAM & WATKINS LLP LETTERHEAD)



     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-Certain U.S. Federal Income
Tax Considerations" constitute the opinion of Latham & Watkins LLP as to the
material United States federal income tax consequences of an investment in the
Notes or the Common Shares received upon the exercise of Notes.

     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 captions "Legal
Matters" 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


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</DOCUMENT>
