EXHIBIT 5.1 INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY DISTRICT DIRECTOR 31 HOPKINS PLAZA BALTIMORE, MD 21201-0000 Date: Dec. 10, 1992 Employer Identification Number: 94-2626437 File folder Number: 521018434 INTEL PUERTO RICO, INC. Person to Contact: KARL ZORIC SEE ATTACHMENT I Contact Telephone Number: (410) 962-0704 c/o MRS. SOLEDAD REICHARD Plan Name: THE INTEL PUERTO RICO MCCONNELL VALDES KELLEY RETIREMENT SAVINGS PLAN SIFRE GRIGG Plan Number: 102 PO BOX 364225 SAN JUAN, PR 00936-4225 Dear Applicant: We have made a favorable determination on your plan, identified above, based on the information supplied. Please keep this letter in your permanent records. Continued qualification of the plan under its present form will depend on its effect in operation. (See section 1.401-1(b)(3) of the Income Tax Regulations.) We will review the status of the plan in operation periodically. The enclosed document explains the significance of this favorable determination letter, points out some features that may affect the qualified status of your employee retirement plan, and provides information on the reporting requirements for your plan. It also describes some events that automatically nullify it. It is very important that you read the publication. This letter relates only to the status of your plan under the Internal Revenue Code. It is not a determination regarding the effect of other federal or local statutes. This determination is subject to your adoption of the proposed amendments submitted in your letter dated November 16, 1992. The proposed amendments should be adopted on or before the date prescribed by the regulations under Code section 401(b). This determination letter is also applicable for the amendment(s) adopted on September 26, 1991. This letter is based upon the certification and demonstrations you submitted pursuant to Revenue procedure 91-66. Therefore, the certification and demonstrations are considered an integral part of this letter. Accordingly, YOU MUST KEEP A COPY OF THESE DOCUMENTS AS A PERMANENT RECORD OR YOU WILL NOT BE ABLE TO RELY ON THE ISSUES DESCRIBED IN REVENUE PROCEDURE 91-66. We have sent a copy of this letter to your representative as indicated in the power of attorney. If you have questions concerning this matter, please contact the person whose name and telephone number are shown above. Sincerely yours, /s/District Director District Director Enclosures: Publication 794 PWBA 515