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                                                                     EXHIBIT 8



                                ___________, 1999

The Barbers Hairstyling for Men & Women, Inc.
300 Industrial Boulevard N.E.
Minneapolis, MN 55413

Ladies and Gentlemen:

         We have acted as counsel to you, The Barbers Hairstyling for Men &
Women, Inc. (the "Company"), in connection with the transaction (the "Merger")
whereby Regis Merger Sub, Inc. ("Merger Sub"), a direct, wholly-owned subsidiary
of Regis Corporation ("Regis"), will merge with and into the Company pursuant to
that certain Agreement and Plan of Merger dated as of January 25, 1999 (the
"Agreement") among Regis, Merger Sub, and the Company. We are delivering this
opinion, relating to certain federal income tax consequences of the Merger,
pursuant to Section 6.2(k) of the Agreement. Terms used herein but not defined
herein have the same meaning as in the Agreement.

         In the Merger, Merger Sub shall be merged with and into the Company by
a statutory merger in accordance with the Minnesota Business Corporation Act
(the "MBCA"). The separate existence of Merger Sub shall cease and the Company
shall be the surviving entity. Pursuant to the Agreement, each share of Company
Common Stock which shall be outstanding immediately prior to the Merger shall be
converted into a portion of a share of Common Stock, $.05 par value per share,
of Regis ("Regis Stock"). In addition, each share of Merger Sub stock
outstanding immediately prior to the Merger shall be converted into a share of
Company Common Stock. No fractional shares of Regis Stock shall be issued in the
Merger, but instead fractional shares shall be converted into cash. Company
shareholders may exercise dissenter's rights in accordance with the MBCA.

         In rendering our opinion, we have examined and relied upon the accuracy
and completeness of the facts, information, covenants, representations, and
warranties contained in originals or copies, certified or otherwise, identified
to our satisfaction, of the Agreement, the combined Proxy Statement of the
Company and Prospectus of Regis (the "Proxy Statement/Prospectus") which is
included in the Registration Statement on Form S-4, Registration No. _________,
filed on ___________, 1999 with the Securities and Exchange Commission, the
Continuity of Interest Agreements given in connection with the Merger among
Regis, the Company and certain shareholders of the Company who are signatories
thereto, and such other documents, including, but not limited to, schedules
prepared by the Company or the Exchange Agent, as we have deemed necessary or
appropriate as a basis for the opinion set forth below. In addition, as to
certain facts material to our opinion which we did not independently establish
or verify, we have relied upon the accuracy of written representations made by
an authorized officer or representative of each of Regis, the Company, and
Merger Sub in letters dated the date hereof and addressed to us. Our opinion is
conditioned on, among other things, the accuracy and completeness, as of the
Effective Time, of such facts, information, covenants, agreements,
representations, and warranties referred to above.

         In our examination of documents in connection with this opinion, we
have assumed the genuineness of all signatures, the legal capacity of natural
persons, the authenticity of all documents submitted to us as originals, the
conformity to original documents of all documents submitted to us as copies and
the authenticity of the originals of such documents, and that all documents are
legally binding and enforceable in accordance with their terms. In rendering our
opinion, we have also assumed (i) that the 

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The Barbers Hairstyling for Men & Women, Inc.
Page 2
________, 1999

Merger will be consummated (A) in accordance with the Agreement, and that 
none of the material terms or conditions contained therein has been waived or 
modified in any respect and (B) as described in the Proxy/Statement 
Prospectus, and (ii) that the Merger qualifies as a statutory merger under 
the laws of the State of Minnesota. A change or inaccuracy in any of the 
facts or assumptions set forth herein may adversely affect our opinion.

         Our opinion is based upon the Internal Revenue Code of 1986, as amended
(the "Code"), as of the date hereof and currently applicable Treasury
Regulations promulgated under the Code (including proposed Treasury
Regulations), published administrative positions of the Internal Revenue Service
in revenue rulings and revenue procedures, and judicial decisions. Such legal
authorities are all subject to change, either prospectively or retroactively. No
assurance can be provided as to the effect of any such change upon our opinion.

         The opinions set forth herein have no binding effect on the Internal
Revenue Service or the courts. No assurance can be given that, if contested, a
court would agree with the opinions set forth herein. The opinions set forth
herein represent rather our best legal judgment as to the likely outcome of the
issues addressed herein if such issues were litigated.

         Based upon and subject to the foregoing, it is our opinion that the
Merger will qualify as a reorganization within the meaning of Sections
368(a)(1)(A) and 368(a)(2)(E) of the Code and that each of Regis, Merger Sub,
and the Company will be a party to the reorganization within the meaning of
Section 368(b) of the Code.

         In the case of a transaction as complex as the Merger, many federal,
state and local income and other tax consequences arise. We have been asked only
to address the issues specifically set forth in the immediately preceding
paragraph. No opinion is expressed regarding any other issues.

         This opinion letter is being delivered solely for the benefit of the
Company and its shareholders as of the date of the Merger. It may not be relied
upon for any other purpose or by any other person for any purpose without our
prior written consent.

         We hereby consent to the filing of a copy of this opinion with the
Registration Statement and to the reference to our firm contained in the
Registration Statement.

                                        Very truly yours,

                                        GRAY, PLANT, MOOTY,
                                              MOOTY & BENNETT, P.A.


