SecProbe.io

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August 16, 2024

VIA EDGAR

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549

 Attn: David L. Orlic

Jeff Long

 RE: The Gabelli Global Utility & Income Trust

    (File Nos.: 333-280438; 811-21529 )

Dear Mr. Orlic and Mr. Long:

Thank you for your oral comments regarding your review of the registration
statement on Form N-2 filed on June 24, 2024 (the “Registration Statement”) by The Gabelli Global Utility & Income
Trust (the “Fund”) with the U.S. Securities and Exchange Commission (the “SEC”). The Fund has considered
your comments and authorized us to respond on its behalf as set forth below. Changes to the Registration Statement will be reflected in
Pre-Effective Amendment No. 1 to the Registration Statement (the “Amendment”), which the Fund intends to file on or
about the date hereof, and will be marked to show all changes made since the initial filing of the Registration Statement.

Your oral comments are summarized
in bold to the best of our understanding, followed by the Fund’s responses. Capitalized terms not otherwise defined herein have
the meanings ascribed to them in the Registration Statement.

*          *          *

Division of Investment Management

U.S. Securities and Exchange Commission

August 16, 2024

Page 2

Disclosure Comments

 1. Please demonstrate in your response that the Fund’s market capitalization qualifies it to file the Registration Statement
pursuant to General Instruction A.2.

To file
the Registration Statement pursuant to General Instruction A.2, the Fund must meet the requirements of General Instruction 1.A of Form
S-3. Among other things, General Instruction 1.A of Form S-3 requires an issuer to aggregate market value of the voting and non-voting
common equity held by non-affiliates of $75 million or more.

The Instruction to this item in Form
S-3 notes that “aggregate market value of the registrant’s outstanding voting and non-voting common equity shall be computed
by use of the price at which the common equity was last sold, or the average of the bid and asked prices of such common equity, in the
principal market for such common equity as of a date within 60 days prior to the date of filing.”

The below sets forth the calculation
of the Fund’s market capitalization in accordance with such requirements:

    Shares outstanding:

    5,968,911

    Shares held by Mario J. Gabelli

    78,053

    Shares held by Associated Capital Group, Inc.

    486,810

    Shares held by Officers and Trustees

    10,986

    Shares held by Non-Affiliates:

    5,393,062

    Market Price as of May 22, 2024:

    $14.88

    Aggregate Market Value:

    $80,248,763

 2. Please update the data under the heading “Price Range of Common Shares.”

The Fund has revised disclosure as requested.

 3. Please provide a draft of the validity opinion at least five days before the requested effectiveness
date of the registration statement.

The Fund will provide
a draft of the validity opinion as requested.

 4. The power of attorney filed as an exhibit to the Registration Statement is undated. Please re-file
with the date inserted.

The power of attorney
has been re-filed.

Division of Investment Management

U.S. Securities and Exchange Commission

August 16, 2024

Page 3

 5. Please confirm that there are no material changes to the forms of prospectus supplements filed with
the Registration Statement relative to the forms of prospectus supplements filed with the Fund’s prior shelf registration statement.

The Fund confirms
that there are no material changes to the forms of prospectus supplements.

Accounting Comments

 6. Include hyperlinks to information incorporated by reference.

The Fund has included
the requested hyperlinks.

 7. The N-CSR for the fiscal year ended December 31, 2023 did not include an auditors consent. Amend the
N-CSR to include an auditors consent.

The auditors consent
was inadvertently omitted from the Fund’s N-CSR for the fiscal year ended December 31, 2023. An amended N-CSR was filed on August
1, 2024 in order to file the auditors consent.

* * * * * * *

Should you have any additional comments or
concerns, please do not hesitate to contact me at (312) 407-0641.

  Best regards,

  /s/ Kevin T. Hardy

  Kevin T. Hardy