EXHIBIT 8.1SUBSIDIARIESThe full corporate name, jurisdiction of incorporation and registered and beneficial ownership ofthe issued and outstanding shares of each direct and indirect Subsidiary is as follows:       **Jurisdiction of**  **Name of Subsidiary** **Incorporation** **Ownership of Securities**Mitel Networks Holdings Limited United Kingdom Wholly-owned by the Corporation     Mitel Networks Asia Pacific Limited Hong Kong Wholly-owned by the Corporation     Mitel Networks International Limited Barbados Wholly-owned by the Corporation     Mitel Networks Overseas Limited Barbados Wholly-owned by the Corporation     Mitel Networks Limited United Kingdom Wholly-owned by Mitel NetworksHoldings Limited, which is inturn wholly-owned by theCorporation     Mitel Networks SARL France Wholly-owned by Mitel NetworksLimited, which is in turnwholly-owned by Mitel NetworksHoldings Limited, which is inturn wholly-owned by theCorporation     Mitel Networks Italia SRL Italy Wholly-owned by Mitel NetworksLimited, which is in turnwholly-owned by Mitel NetworksHoldings Limited, which is inturn wholly-owned by theCorporation     Mitel Networks, Inc. Delaware Wholly-owned by Mitel U.S.Holdings, Inc., which is inturn wholly-owned by theCorporation     Mitel Networks Germany GmbH Germany Wholly-owned by Mitel NetworksLimited, which is in turnwholly-owned by Mitel NetworksHoldings Limited, which is inturn wholly-owned by theCorporation     Mitel Telecom Limited United Kingdom Wholly-owned by Mitel NetworksLimited, which is in turnwholly-owned by Mitel NetworksHoldings Limited, which is inturn wholly-owned by theCorporation     Mitel Financial Services Limited United Kingdom 25% owned by First AssetFinance PLC; 75% owned byMitel Networks Limited, whichis in turn wholly-owned byMitel Networks HoldingsLimited, which is in turnwholly-owned by theCorporation     Mitel Networks (México), S.A. de C.V. Mexico Wholly-owned by the Corporation     Mitel Comércio e Serviços do Brasil Ltda. Brazil Wholly-owned by the Corporation
 

 
       **Jurisdiction of**  **Name of Subsidiary** **Incorporation** **Ownership of Securities**Mitel U.S. Holdings, Inc. Delaware Wholly-owned by the Corporation     Inter-Tel Delaware Incorporated Delaware Wholly-owned by Mitel U.S.Holdings, Inc., which is inturn wholly-owned by theCorporation     Inter-Tel Netsolutions, Inc. Texas Wholly-owned by Inter-TelDelaware Incorporated, whichis in turn wholly-owned byMitel U.S. Holdings, Inc.,which is in turn wholly-ownedby the Corporation     Inter-Tel Leasing, Inc. Arizona Wholly-owned by Inter-TelDelaware Incorporated, whichis in turn wholly-owned byMitel U.S. Holdings, Inc.,which is in turn wholly-ownedby the Corporation     Inter-Tel Business Information Systems, Inc. Arizona Wholly-owned by Inter-TelDelaware Incorporated, whichis in turn wholly-owned byMitel U.S. Holdings, Inc.,which is in turn wholly-ownedby the Corporation     Inter-Tel Technologies, Inc. Arizona Wholly-owned by Inter-TelDelaware Incorporated, whichis in turn wholly-owned byMitel U.S. Holdings, Inc.,which is in turn wholly-ownedby the Corporation     Inter-Tel Lake Limited Republic of Ireland Wholly-owned by Inter-TelDelaware Incorporated, whichis in turn wholly-owned byMitel U.S. Holdings, Inc.,which is in turn wholly-ownedby the Corporation     Inter-Tel Integrated Systems, Inc. Arizona Wholly-owned by Inter-TelDelaware Incorporated, whichis in turn wholly-owned byMitel U.S. Holdings, Inc.,which is in turn wholly-ownedby the Corporation     Swan Solutions Limited United Kingdom Wholly-owned by Inter-TelIntegrated Systems, Inc.,which is in turn wholly-ownedby Inter-Tel DelawareIncorporated, which is in turnwholly-owned by Mitel U.S.Holdings, Inc., which is inturn wholly-owned by theCorporation