Exhibit 8.1

 

				King & Spalding LLP 1290 Avenue of the Americas New York, New York 10104 T: +1 212 556 2100 F: +1 212 556 2222 www.kslaw.com

March 16, 2026

MasterCraft Boat Holdings, Inc.

100 Cherokee Cove Drive

Vonore, TN 37885

Re: Exhibit 8.1 Tax Opinion

Ladies and Gentlemen:

We have acted as counsel to MasterCraft Boat Holdings, Inc., a Delaware corporation (“MasterCraft”), in connection with (i) the transactions contemplated by the Agreement and Plan of Merger (the “Merger Agreement”), dated as of February 5, 2026, by and among MasterCraft, Titan Merger Sub 1, Inc., a Delaware corporation and a wholly owned, direct Subsidiary of MasterCraft (“Merger Sub 1”), Titan Merger Sub 2, LLC, a Delaware limited liability company and a wholly owned, direct Subsidiary of MasterCraft (“Merger Sub 2”), and Marine Products Corporation, a Delaware corporation (the “Company”), and (ii) the preparation of a Registration Statement on Form S-4 filed by MasterCraft on the date hereof with the Securities and Exchange Commission, including the proxy statement/prospectus forming a part thereof (the “Registration Statement”). Except as otherwise provided, capitalized terms used but not defined herein have the meaning ascribed to them in the Merger Agreement.

Subject to the terms and conditions of the Merger Agreement, (i) Merger Sub 1 will merge with and into the Company (the “First Merger”) with the Company surviving as a direct, wholly owned subsidiary of MasterCraft and (ii) immediately following the completion of the First Merger, the Company will merge with and into Merger Sub 2, with Merger Sub 2 surviving as a direct, wholly owned subsidiary of MasterCraft (the “Second Merger” and, together with the First Merger, the “Mergers”). In rendering our opinion below, we have examined, and are expressly relying upon (without any independent investigation or review thereof) the truth and accuracy of the factual statements, representations, covenants, and warranties contained in (i) the Merger Agreement (including any exhibits and schedules thereto), (ii) the Registration Statement, (iii) the representation letter of the Company, dated as of the date hereof, and the representation letter of MasterCraft (on behalf of itself, Merger Sub 1 and Merger Sub 2), dated as of the date hereof, each delivered to us for purposes of this opinion (the “Representation Letters”) and (iv) such other documents and records as we have deemed necessary or appropriate in order to give the opinion set forth herein. In addition, we have made certain assumptions, including that:

1. any original documents submitted to us (including signatures thereto) are authentic, and documents submitted to us as copies conform to the original documents, and there has been (or will be by the effective time of the Mergers) execution and delivery of all documents in the form presented to us;

March 16, 2026

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2. the Mergers and any related transactions will be consummated in the manner contemplated by, and in accordance with the provisions of, the Merger Agreement and the other agreements referred to therein (the “Transaction Documents”) and as described in the Registration Statement (and no covenants or conditions described therein and affecting this opinion will be waived or modified), and the Mergers and any related transactions will be effective under the laws of the State of Delaware and any other applicable jurisdiction;

3. all factual statements, descriptions, and representations contained in any of the Transaction Documents, the Registration Statement, the Representation Letters and any other documents or records on which we have relied, are true, complete, and correct in all respects and will remain true, complete, and correct in all respects up to and including the effective time of the Mergers and no actions have been taken or will be taken that are inconsistent with such factual statements, descriptions, or representations or that make any such factual statements, descriptions, or representations untrue, incomplete or incorrect at the effective time of the Mergers;

4. any certificates, forms or other documentation that any of parties to the Merger Agreement have requested, or will request, from any person in connection with the Mergers will have been duly executed and provided to the requesting party as and when requested;

5. any representations or statements made in any of the Transaction Documents, the Registration Statement or the Representation Letters qualified by knowledge, belief, expectation, intent, or materiality or comparable qualifiers are true, complete, and correct in all respects and will continue to be true, complete, and correct in all respects at all times up to and including the effective time of the Mergers, in each case without such qualification;

6. the Transaction Documents represent the entire understanding of the parties with respect to the Mergers and any related transactions, and there are no other written or oral agreements regarding the Mergers other than the Transaction Documents;

7. the parties to the Merger Agreement have complied with and, if applicable, will continue to comply with, the covenants contained in the Merger Agreement; and

8. all applicable reporting requirements with respect to the Mergers have been or will be satisfied.

If any of the assumptions described above are untrue for any reason, or if the Mergers are consummated in a manner that is different from the manner described in the Merger Agreement or the Registration Statement, our opinion as expressed below may be adversely affected.

March 16, 2026

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We express no opinion on any issue or matter relating to the tax consequences of the transactions contemplated by the Merger Agreement, including any transactions that may occur after the Closing, or described in the Registration Statement other than the opinion set forth below. We are opining herein only as to the U.S. federal income tax matters described below, and we express no opinion with respect to the applicability to, or the effect on, any transaction of other federal laws, foreign 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. This opinion is based on current provisions of the Internal Revenue Code of 1986, as amended (the “Code”), the legislative history thereto, the Treasury 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 or differing interpretations, either prospectively or retroactively. Any change in applicable law, or any variation or difference in the information, facts, statements, representations, covenants, and undertakings on which we have relied may affect the continuing validity of this opinion. We assume no responsibility to inform you of any such change or inaccuracy that may occur or come to our attention (or to supplement or revise our opinion to address any such change or inaccuracy) subsequent to the date hereof.

Based upon and subject to the foregoing and subject to the assumptions, representations, qualifications, and limitations set forth herein and in the Registration Statement, we are of the opinion that the Mergers, taken together, will qualify as a “reorganization” within the meaning of Section 368(a) of the Code.

This opinion is rendered to MasterCraft solely in connection with the filing of the Registration Statement. We hereby consent to the filing of this opinion of counsel as Exhibit 8.1 to the Registration Statement and the use of our name in the Registration Statement. In giving such consent, we do not admit that we are within the category of persons whose consent is required under Section 7 of the Securities Act of 1933, as amended.