SecProbe.io

CORRESP
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    Kimberly L. Broder

    212.756.2226

    Kimberly.Broder@srz.com

September 25, 2023

VIA E-MAIL AND EDGAR

    Ms. Karen Rossotto

    Division of Investment Management

    100 F Street, NE

    U.S. Securities and Exchange Commission

    Washington, D.C. 20549

    Re:

    Templeton Global Income Fund

    Response to Comments on September 22, 2023 with respect to the Definitive
    Proxy Statement on Schedule 14A filed on September 20, 2023

    File No. 811-05459

Dear Ms. Rossotto:

On behalf of Templeton
Global Income Fund (the “Filing Person” or the “Fund”), we are responding to your phone call on
September 22, 2023 (the “SEC Comment Phone Call”) in connection with the Definitive Proxy Statement on Schedule 14A
filed on September 20, 2023 (the “Definitive Proxy Statement”). We have reviewed the comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “SEC”) and respond below. For your convenience, the Staff’s comments
are restated below in italics, with our responses following.

The Filing Person,
after making the appropriate revisions in response to the Staff’s comments, intends to file its revised definitive proxy
statement. Capitalized terms used but not defined herein have the meaning ascribed to such terms in the Definitive Proxy
Statement.

1. In the shareholder letter, please explain
what is going on here in plain English for shareholders’ understanding. In addition, please summarize and highlight the proposed
changes, so that the shareholders can understand that voting for the new investment management agreement will result in changes to the
Fund’s name and strategy as well as the advisor, and mention that these changes may impact the Fund’s risks.

In response to the Staff’s
first part of the comment, the Filing Person revised the third paragraph of the shareholder letter to provide more explanation in plain
English regarding the establishment of special committee and the resultant RFP.

In response to the Staff’s
second part of the comment, the Filing Person added the following paragraph summarizing the proposed changes in a bulleted list under
the bolded and underlined title “Proposed Changes”, and added a cross-reference to the response to Q8 for the risks associated
with the proposed changes.

Proposed Changes

 · There is no proposed change to the Fund’s investment objective of seeking high current income and
capital appreciation.

 · Shareholders are being asked to make the Fund’s investment objective
                                                                                                             “non-fundamental” in order to provide the Fund with greater investment flexibility subsequent to the Adviser Transition,
                                                                                                             such that in the event a change in the objective is sought in the future, which is not currently expected, the Board can make
                                                                                                             the determination without shareholder approval.

    Ms. Rossotto

Page 2

September 25,2023

 · If Shareholders approve the New Management Agreement, upon the Adviser Transition, the Fund would also
expand its principal investment strategy to invest globally in debt and equity securities of public and private companies, which includes,
among other things, investments in closed-end funds, special purpose acquisition companies, and public and private debt instruments. The
expanded strategy would also allow the Fund to utilize derivatives, including total return swaps, credit default swaps, options and futures,
in seeking to enhance returns and/or to reduce portfolio risk. In addition, on an opportunistic basis, the Fund may also invest up to
15% of its total assets in private funds that focus on debt, equity or other investments consistent with the Fund’s investment objective.

 · In light of the aforementioned expanded strategy, shareholders are also being asked to remove the Fund’s
current fundamental policy mandating that at least 65% of the Fund’s total assets be invested in at least three countries and in
various types of debt instruments.

 · Following the completion of the Adviser Transition, the Fund’s name will change to “Saba Capital
Income & Opportunities Fund II”. The common shares of the Fund will continue to be listed on the New York Stock Exchange, although
the ticker symbol will change upon the change in the name of the Fund to “SABA”.

These proposed changes may result in
corresponding changes to the Fund’s risk profile. For the risks associated with the proposed changes in the investment strategy
upon the Adviser Transition, please refer to our response to Q18 in the Q&A section of the Proxy Statement.

2. In the last sentence
of the shareholder letter, please explain for the shareholders what “non-fundamental” policy means.

In response to the Staff’s
comment, the Filing Person clarified the term “non-fundamental” by adding that “in the event a change in the objective
is sought in the future, which is not currently expected, shareholder approval would not be required.”

3. In the notice of special
meeting, please reference or cross-reference how the shareholders may revoke their votes.

In response to the Staff’s
comment, the Filing Person added the following paragraph:

“You may change your mind after
you send in your proxy card or authorize your shares by telephone, through the Internet or at the Special Meeting by following these procedures.
Please refer to our response to Q18 in the Q&A section below for details on how to revoke your proxy.”

4. Please consider clarifying
the following sentence: “Even if you vote your shares prior to the Special Meeting, you still may attend the meeting virtually and
vote your shares.”

In response to the Staff’s
comment, the Filing Person revised the sentence as follows to clarify: “Even if you vote your shares prior to the Special Meeting,
you still may attend the meeting virtually and change your vote.”

5. We note the use of
term “Unaffiliated Board” throughout your disclosure. To the extent that the trustees nominated by Saba to the Board are
considered unaffiliated, please explain why in your disclosure.

    Ms. Rossotto

Page 3

September 25,2023

 In response to the
Staff’s comment, the Filing Person added the below paragraph to “Conflicts of Interests of Our Trustees and Officers in the
Adviser Transaction” under Proposal I to explain why the trustees nominated or recommended by Saba to the Board are considered
unaffiliated:

“Each of Ms. Caldwell and
Messrs. Desai, Gabriel, Nakum and Hammit was nominated to the Board as an independent trustee by Saba. Mr. Khasidy was appointed to
the Board on March 15, 2023 to serve as an independent trustee of the Board. Each of these members of the Unaffiliated Board (as
this term is used throughout this Proxy Statement) is neither an “interested person” of the Fund nor of Saba as such
term is defined under Section 2(a)(19) of the 1940 Act. None of these individuals is or was employed by Saba, receives any
compensation from Saba, or is otherwise affiliated with Saba.”

6. In your response to
Q6 in the Q&A section, please clearly explain the new strategy, investment type and related risks that Saba is proposing for the Fund.

In response to the Staff’s
comment, the Filing Person added a cross-reference to “Q8: How will the Adviser Transition affect the Fund’s investment object
and strategy?”, which lays out in detail the new strategy and investment type. In addition, we revised our response to Q8 to include
the below discussion of the related risks.

As a result of the proposed modified strategy, the
Fund would be subject to additional principal risks associated with the following investments, among others, to which the Fund is not
materially subject at this time:

 · Equity Securities. The Fund may suffer losses if it invests in equity instruments of issuers whose
performance diverges from the investment advisor’s expectations or if equity markets generally move in a single direction and the
Fund has not hedged against such a general move.

 · Closed-End Fund. To the extent that the portfolio CEFs invest in financial instruments similar
to those invested in by the Fund, the risk factors that are set forth herein with respect to such instruments will also apply to the CEFs
in which the Fund invests, and thus indirectly apply to the Fund.

 · Private Securities, including Private Funds. The sale of private securities often requires more
time and results in higher selling expenses than does the sale of public securities. Realization of value from such investments may be
difficult in the short-term, or may have to be made at a substantial discount compared to other freely tradable investments.

 · Distressed Securities. The Fund expects to invest in below investment grade
                                                                                                             securities and obligations of issuers in weak financial condition. Certain debt instruments purchased may be non-performing and possibly in
                                                                                                             default. In any reorganization or liquidation proceeding, the Fund may lose its entire investment, may be required to accept cash or
                                                                                                             securities with a value less than the Fund's original investment and/or may be required to accept payment over an extended period of
                                                                                                             time.

 · High-Yield Securities. The Fund expects to invest in bonds or other fixed income securities, including,
without limitation, "higher yielding" (including non-investment grade) debt securities, and may take short positions in these
securities. High-yield securities face ongoing uncertainties and exposure to adverse business, financial or economic conditions which
could lead to the issuer's inability to meet timely interest and principal payments and are subject to price volatility resulting from,
among other things, interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity.

    Ms. Rossotto

Page 4

September 25,2023

 · Short Selling. A short sale involves the risk of a theoretically unlimited loss, in that the price
of the underlying security could theoretically increase without limit, thus increasing the cost to the Fund of buying those securities
to cover the short position or resulting in the inability of the Fund to cover the short position.

   • Index or Index Options.
                                            An index or index option fluctuates with changes in the market values of the securities included
                                            in the index. In addition, because the value of an index or index option depends upon movements
                                            in the level of the index rather than the price of a particular asset, whether the Fund will
                                            realize gains or losses from the purchase or writing of options on indices depends upon movements
                                            in the level of instrument prices in the assets generally or, in the case of certain indices,
                                            in an industry or market segment, rather than movements in the price of particular assets.

7. In your response to
Q6 in the Q&A section, please clarify whether and how the Board considered the fees charged to BRW when approving the new investment
advisor agreement.

In response to the Staff’s
comment, the Filing Person added the below sentence to the end of Q6 and substantively the same sentence to “Fees and Expenses”
section of Proposal I.

“In addition, the Unaffiliated Board,
as well as the Special Committee, considered that the proposed fees under the New Management Agreement are lower than the management fees
payable by BRW.”

8. In your response to
Q12 in the Q&A section, please determine if the total cost will go up as a result of the change in administration fees, and if so,
please disclose as such.

In response to the Staff’s
comment, the Filing Person added that “[the administration] fees will be incremental to the management fees borne by the Fund and
thus will cause the Fund’s net expense ratio to be somewhat higher after the Adviser Transition.”

9. In your response to
Q19 in the Q&A section, please determine whether the shareholders of shares held in street name can attend the special meeting, and
if so, please disclose as such and how they may do so.

In response to the Staff’s
comment, the Filing Person added the below sentence clarifying that the shareholders of shares held in street name can attend the special
meeting and how they may do so:

“Alternatively, [the shareholders
of shares held in street name] can access the virtual meeting and vote your shares yourself using the unique 16 digit control number printed
on the enclosed proxy card. If you have lost or misplaced the unique control number, you can requested it directly from your bank, brokerage
firm or other nominee.”

    Ms. Rossotto

Page 5

September 25,2023

10. In your response
to Q21 in the Q&A section, please disclose that the approval of each proposal is independent of approval of any other proposal.

In response to the Staff’s
comment, the Filing Person added to the response to Q21 and the “Purpose of Meeting” section of the Proxy Statement a footnote
disclosing that the approval of each proposal is independent of approval of any other proposal.

11. In the last paragraph
of your response to Q21 in the Q&A section, please clarify what percentage of outstanding shares Saba has discretionary voting authority
over, and explain in correspondence how that ownership and voting fit under Section 12(d)(1) of the 1940 Act.

In response to the second
part of Staff’s comment, the Filing Person revised the paragraph in the response to Q21, as well as a substantively same paragraph
under “Conflicts of Interests of Our Trustees and Officers in the Adviser Transition” in Proposal I, to clarify that Saba
has discretionary voting authority over 27.26% of the outstanding shares of the Fund.

In response to the second
part of Staff’s comment, the Filing Person note that no Saba-managed fund acquired any shares of the Fund in contravention of the
3% limitation to which such fund is subject under Section 12(d)(1) of the 1940 Act.

12. For the same paragraph,
please clarify what “echo voted” means and how are the remaining proxies expected to be voted.

In response to the Staff’s
comment, the Filing Person explained that the echo vote means voting in the same proportion as the vote of all other shareholders.

13. For the second paragraph
of the Background section of the Proposal I, to the extent that Saba’s ownership has impacted any RFP, please explain how the special
committee thought to address that impact.

In response to the Staff’s
comment, the Filing Person respectfully note that Saba’s ownership did not impact any RFP, except that Saba was included in the
RFP process because of its ownership and prior expression of a desire to manage the Fund.

14. In the “Performance”
section of the Proposal I, please explain how BRW’s return compared to the Fund’s return over the relevant period.

In response to the Staff’s
comment, the Filing Person added a disclosure that BRW substantially outperformed the Fund for the period since Saba assumed portfolio
management responsibility over BRW (June 2021) through June 30, 2023. In addition, the Filing Person included a footnote
with the data and the citation to the source of such data.

15. In t