Exhibit 8.1

Liberty Media Corporation
12300 Liberty Boulevard
Englewood, Colorado 80112  

Ladies and Gentlemen:

We have acted as special tax counsel to Liberty Media Corporation, a Delaware corporation (“Liberty”), in connection with specified aspects of (i) the transfer of 10,488,960 shares of Live Nation Entertainment, Inc. (“Live Nation”) common stock by Liberty to LN Holdings 1, LLC, a newly formed Delaware limited liability company wholly owned by Liberty Live Holdings, Inc., a newly formed Nevada corporation (“SplitCo”), in exchange for the constructive issuance of SplitCo stock to Liberty (the “First SplitCo Contribution”); (ii) the contribution of the remaining assets attributed to Liberty’s Live Group by Liberty to SplitCo (including the remaining shares of Live Nation common stock owned by Liberty and Liberty’s interest in QuintEvents, LLC) in exchange for the constructive issuance of SplitCo stock and the assumption by SplitCo of certain liabilities attributed to Liberty’s Live Group (together with the First SplitCo Contribution, the “SplitCo Contribution”); (iii) the recapitalization of SplitCo’s outstanding stock into a number of shares of SplitCo’s Series A Liberty Live Group common stock (“Series A SplitCo Common Stock”), SplitCo’s Series B Liberty Live Group common stock (“Series B SplitCo Common Stock”), and SplitCo’s Series C Liberty Live Group common stock (“Series C SplitCo Common Stock,” and together with the Series A SplitCo Common Stock and Series B SplitCo Common Stock, “SplitCo Common Stock”) sufficient to effect the Split-Off (as defined below) (the “SplitCo Recapitalization”); and (iv) the distribution by Liberty of (A) all of the outstanding Series A SplitCo Common Stock to the holders of Liberty’s Series A Liberty Live common stock (“Series A Liberty Live Common Stock”) in complete redemption of the outstanding Series A Liberty Live Common Stock, (B) all of the outstanding Series B SplitCo Common Stock to the holders of Liberty’s Series B Liberty Live common stock (“Series B Liberty Live Common Stock”) in complete redemption of the outstanding Series B Liberty Live Common Stock, and (C) all of the outstanding Series C SplitCo Common Stock to the holders of Liberty’s Series C Liberty Live common stock (“Series C Liberty Live Common Stock,” and together with the Series A Liberty Live Common Stock and Series B Liberty Live Common Stock, “Liberty Live Common Stock”) in complete redemption of the outstanding Series C Liberty Live Common Stock (such redemptions, collectively, the “Split-Off,” and together with the SplitCo Contribution, the SplitCo Recapitalization, and certain related transactions, the “Transactions”). Liberty has requested our opinion (the “Opinion”) regarding certain U.S. federal income tax consequences of the Transactions.¹

Liberty Media Corporation

December 15, 2025

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In rendering this Opinion, we have examined originals or copies, certified or otherwise identified to our satisfaction, of (i) the letter furnished to Liberty by its financial advisor with respect to the Transactions, dated as of the date hereof; (ii) the registration statement on Form S-4 (File No. 333-288960) filed by SplitCo with the Securities and Exchange Commission (the “SEC”) on July 25, 2025, including the proxy statement/notice/prospectus that forms a part thereof and the exhibits attached thereto, as amended through the date hereof (the “Registration Statement”); (iii) all other submissions to the SEC related to the Registration Statement; (iv) the agreements listed on Schedule A attached hereto (each as amended through the date hereof) (collectively, the “Agreements”); (v) the officer’s certificate furnished to us by Liberty, dated as of the date hereof, together with the exhibits attached thereto (the “Liberty Officer’s Certificate”); (vi) the officer’s certificate furnished to us by SplitCo, dated as of the date hereof, together with the exhibits attached thereto (the “SplitCo Officer’s Certificate,” and together with the Liberty Officer’s Certificate, the “Officer’s Certificates”); (vii) the representation letter furnished to us by Mr. John C. Malone, dated as of the date hereof (the “Malone Representation Letter”); and (viii) such other documents as we have considered necessary or appropriate as a basis for this Opinion. In our examination, we have assumed the genuineness of all signatures, the legal capacity of all natural persons, the authenticity of all documents submitted to us as originals, the conformity to originals of all documents submitted to us as certified, photostatic, electronic, or facsimile copies, and the authenticity of the originals of such documents.

Liberty Media Corporation

December 15, 2025

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As to certain facts material to this Opinion, we have relied upon the statements and representations set forth in the Officer’s Certificates and the Malone Representation Letter. We have assumed that such statements and representations are true, correct, and complete as of the date hereof and will continue to be true, correct, and complete without regard to any qualification as to knowledge, belief, or otherwise. We have also assumed that the Transactions and the other transactions contemplated by the Agreements will be consummated in accordance with their terms and in the manner described in the Registration Statement and the Agreements, that the Agreements are and will be legally binding on the parties, and that none of the material terms or conditions contained therein will be waived or modified in any respect. This Opinion is expressly conditioned upon, among other things, the initial and continuing accuracy of the facts, information, covenants, representations, and warranties set forth in the documents referred to above, including those contained in the Officer’s Certificates and the Malone Representation Letter. Any change or inaccuracy in or to such facts, information, covenants, representations, or warranties (including on account of events occurring after the consummation of the Transactions) could affect one or more of the conclusions stated herein.

This Opinion is based on the Code, the Treasury Regulations, judicial decisions, published rulings and procedures of the Internal Revenue Service (the “Service”), and such other authorities as we have considered relevant, all as in effect on the date hereof. It should be noted that the authorities upon which this Opinion is based are subject to change at any time, possibly with retroactive effect. Any change in such authorities could affect one or more of the conclusions expressed herein. Moreover, an opinion of counsel represents counsel’s best judgment as to the outcome on the merits with respect to the matters addressed therein. Opinions of counsel are not binding on courts or the Service, and there can be no assurance that this Opinion will be accepted by the Service or, if challenged, by a court.

Based upon and subject to the foregoing and the conditions, limitations, assumptions, and qualifications set forth herein, it is our opinion that, under current U.S. federal income tax law:

Liberty Media Corporation

December 15, 2025

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Liberty Media Corporation

December 15, 2025

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Except as set forth above, we express no opinion or other views regarding the tax consequences of the Transactions or any other transactions. This Opinion relates solely to the U.S. federal income tax consequences of the Transactions, and no opinion is expressed as to the tax consequences of the Transactions under any state, local, or foreign tax laws or under any U.S. federal tax laws other than those pertaining to income taxation. This Opinion is expressed as of the date hereof, and we are under no obligation to supplement or revise this Opinion to reflect any legal developments or factual matters or changes arising after the date hereof.

We are furnishing this Opinion to Liberty solely in connection with the Transactions and the Registration Statement. We hereby consent to the use of our name in the Registration Statement and to the filing of this Opinion as an exhibit to the Registration Statement. In giving this consent, we do not admit that we come within the category of persons whose consent is required under section 7 of the Securities Act of 1933, as amended, or the rules and regulations of the SEC thereunder.