SecProbe.io

CORRESP
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corresp

February 18, 2010

Mr. Larry Greene

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Calamos Global Total Return Fund

333-146944

811-21547

Dear Mr. Greene:

     This letter responds to the comments you verbally conveyed to me on October 8, 2009, regarding
post-effective amendment no. 2 to the registration statement on Form N-2 of Calamos Global Total
Return Fund (the “Fund”). For convenience, each of your comments is repeated below, with responses
immediately following.

     The revisions to the prospectus, prospectus supplements and statement of additional
information responding to these comments were included in a new Post-Effective Amendment no. 3,
which also updates the Fund’s financial statements.

General

    1.

    Comment: Please provide written responses to the staff’s
comments, filed as a separate piece of EDGAR
correspondence. In addition, please file Tandy
representations as EDGAR correspondence.

    Response: The Fund hereby files these responses to the staff’s comments as separate EDGAR
correspondence. The Fund also hereby files Tandy representations with the Commission in
this correspondence, as Exhibit A hereto.

    2.

    Comment: We note that the Fund has the term “Global” in its name. Please supplementally
verify that the Fund is in compliance with Rule 35d-1 under the Investment Company Act of 1940
(the “1940 Act”).

    Response: The Investment Company Names Release No. IC-24828 suggests that a fund that uses
the term “Global” in its name should invest its assets in “investments that are tied
economically to a number of countries throughout the world,” with the

Mr. Larry Greene

February 18, 2010

Page 2

    staff generally interpreting this to require a “global” fund to invest at least 40% of its
assets in non-U.S. securities. During the comment process for the Fund’s initial
registration statement in 2005, we received a comment from the staff regarding the term
“Global” and were able to agree on the language that is currently included in the
prospectus. We believe that the Fund’s policy continues to be in compliance with Rule
35d-1. In addition, as of August 31, 2009, the Fund had over 60% of its managed assets
invested in non-U.S. securities, with eight foreign countries each comprising more than 2%
of the Fund’s portfolio. The Fund’s policy regarding non-U.S. investments, contained on
page 22 of the prospectus, is as follows:

    Under normal circumstances, the Fund will invest at least 30% of its managed assets
in securities of foreign issuers; however, the Fund anticipates that ordinarily
Calamos’ investment process will result in the Fund investing at least 40% of its
managed assets in securities of foreign issuers.

Prospectus

    3.

    Comment: On page ii of the prospectus, the Fund provides a
cautionary notice regarding forward looking
statements. Please consider consolidating the last
sentence of the first paragraph of this discussion
with the last paragraph, which appear to involve
related concepts.

    Response: We have moved the last paragraph on page ii of the prospectus to the end of the
first paragraph.

    4.

    Comment: Please confirm supplementally the staff’s understanding that the phrase “managed
assets” that is used on page 1 of the prospectus includes assets attributable to borrowings.

    Response: We confirm supplementally the staff’s understanding that the phrase “managed
assets” that is used on page 1 of the prospectus includes assets attributable to
borrowings.

    5.

    Comment: On page 1 of the prospectus, the Fund states that it may offer its securities “on an
immediate, continuous, or delayed basis.” Please provide a supplemental explanation that
briefly describes each offering method, and which explains why these methods are not mutually
exclusive.

    Response: The phrase “immediate, continuous, or delayed basis” is taken from Rule
415(a)(1)(x), and it refers to three distinct methods of selling securities. An
“immediate” offering is the offering of a security immediately upon effectiveness of the
registration statement. A “continuous” offering is one in which the issuer sells
securities over an extended period of time. A “delayed” offering is one in which the
issuer registers securities, but does not sell those securities until it subsequently does

Mr. Larry Greene

February 18, 2010

Page 3

    a “take down” of the securities being offered. An offering may involve one or more of
these elements, for example, a delayed, continuous offering would be a continuous offering
that occurred after the securities had been taken down from the shelf.

    Upon effectiveness of the Fund’s post-effective amendment no. 2, or the effectiveness of a
subsequent post-effective amendment, the Fund intends to resume its continuous
at-the-market offering of its common stock, for such periods during which sales are
permitted by Section 23(b) of the Investment Company Act of 1940, in accordance with the
principles articulated in Nuveen Virginia Premium Income Municipal Fund (pub. avail. Oct.
6, 2006). This offering is detailed in the form of prospectus supplement that was filed as
a part of post-effective amendment no. 2. In addition, the Fund has registered securities
for a delayed offering in which it may “take down” securities to sell at a date subsequent
to the effectiveness of post-effective amendment no. 2, or a subsequent post-effective
amendment, also in accordance with the principles articulated in Nuveen Virginia Premium
Income Municipal Fund (pub. avail. Oct. 6, 2006). Also, the Fund reserves the right to do
an immediate take-down from the securities registered for the shelf, which depending on the
circumstances, could be deemed to be an immediate offering.

    As can be seen from this discussion, these methods are complementary are not mutually
exclusive.

    6.

    Comment: On page 1 of the prospectus, the Fund notes that it “paid a one time arrangement fee
of .25% of the total borrowing limit” of its committed facility agreement with BNP Paribas.
Please explain supplementally whether this fee is recurring, or is truly a one-time fee.

    Response: We supplementally confirm that the arrangement fee paid by the Fund in connection
with its committed facility agreement with BNP Paribas was a one-time fee and is not
recurring.

    7.

    Comment: On page 1-2 of the prospectus, and again on pages 56-57 of the prospectus, the Fund
indicates that it has engaged in a Committed Facility Agreement with BNP Paribas Prime
Brokerage, Inc. (“BNP”). The Fund states that pursuant to this agreement, “BNP has the
ability to reregister the collateral in its own name or in another name other than the Fund to
pledge, re-pledge, sell, lend or otherwise transfer or use the collateral (“Hypothecated
Securities”) with all attendant rights of ownership.” Please provide the staff with a
supplemental explanation as to why it believes this arrangement is permissible under Section
17(f) of the 1940 Act.

    Response: The Fund believes that his arrangement meets the elements that the staff’s
previous guidance regarding permissible securities lending arrangements. The arrangement
with BNP involves a borrowing, which will be treated by the Fund as a senior security under
the provisions of Section 18 of the 1940 Act, along with a side

Mr. Larry Greene

February 18, 2010

Page 4

    agreement that creates a securities lending arrangement between the Fund and BNP. The Fund
has structured this securities lending arrangement to comply with various interpretive
letter that the SEC staff has issued over the years with respect to securities lending
arrangements. In particular, the Fund believes that this securities lending arrangement is
similar to that discussed in Morgan Guaranty Trust Co. of New York (pub. avail. Apr. 17,
1996). The Fund believes that the arrangement is permissible under the reasoning of that
letter, and other letters that the SEC’s staff has issued that permit securities lending
arrangements.

    After extensive discussions with the Division of Investment Management’s Office of Chief
Counsel, the Fund has agreed to provide the following disclosure of its arrangement with
BNP in its registration statement. This disclosure will replace similar disclosure
regarding the arrangements with BNP that is currently contained in the Fund’s prospectus.

    The Fund, with the approval of its Board of Trustees, including its independent
Trustees, has entered into a financing package that includes a Committed Facility
Agreement (the “Agreement”) with BNP Paribas Prime Brokerage, Inc. (as successor to
Bank of America N.A.) (“BNP”) that allows the Fund to borrow up to an initial limit
of $59,000,000, and a Lending Agreement, as defined below. The Agreement with BNP
replaced the existing extendible senior secured notes, and an initial draw-down of
$59,000,000 under the Agreement was utilized to pay off outstanding indebtedness
under the extendible senior secured notes in their entirety. Borrowings under the
Agreement are secured by assets of the Fund that are held with the Fund’s custodian
in a separate account (the “pledged collateral”). Interest is charged at the
quarterly LIBOR (London Inter-bank Offered Rate) plus 0.95% on the amount borrowed
and 0.85% on the undrawn balance. For the year ended October 31, 2009, the average
borrowings under the Agreement and the average interest rate were $30,263,014 and
1.98%, respectively. As of October 31, 2009, the amount of such outstanding
borrowings is $30,000,000. The interest rate applicable to the borrowings on
October 31, 2009 was 1.23%.

    The Lending Agreement is a separate side-agreement between the Fund and BNP
pursuant to which BNP may borrow a portion of the pledged collateral (the “Lent
Securities”) in an amount not to exceed the outstanding borrowings owed by the Fund
to BNP under the Agreement. The Lending Agreement is intended to permit the Fund
to significantly reduce the cost of its borrowings under the Agreement. BNP may
re-register the Lent Securities in its own name or in another name other than the
Fund, and may pledge, re-pledge, sell, lend or otherwise transfer or use the Lent
Securities with all attendant rights of ownership. The Fund may designate any
security within the pledged collateral as ineligible to be a Lent Security,
provided there are eligible

Mr. Larry Greene

February 18, 2010

Page 5

    securities within the pledged collateral in an amount equal to the outstanding
borrowing owed by the Fund. During the period in which the Lent Securities are
outstanding, BNP must remit payment to the Fund equal to the amount of all
dividends, interest or other distributions earned or made by the Lent Securities.
BNP will pay to the Fund a fee for borrowing the securities that is calculated as a
percentage of the difference between a fair market rate and a reference rate, with
a guaranteed minimum annualized rate.

    Under the terms of the Lending Agreement, the Lent Securities are marked to market
daily, and if the value of the Lent Securities exceeds the value of the
then-outstanding borrowings owed by the Fund to BNP under the Agreement (the
“Current Borrowings”), BNP must, on that day, either (1) return Lent Securities to
the Fund’s custodian in an amount sufficient to cause the value of the outstanding
Lent Securities to equal the Current Borrowings; or (2) post cash collateral with
the Fund’s custodian equal to the difference between the value of the Lent
Securities and the value of the Current Borrowings. If BNP fails to perform either
of these actions as required, the Fund will recall securities, as discussed below,
in an amount sufficient to cause the value of the outstanding Lent Securities to
equal the Current Borrowings. The Fund can recall any of the Lent Securities and
BNP shall, to the extent commercially possible, return such security or equivalent
security to the Fund’s custodian no later than three business days after such
request. If the Fund recalls a Lent Security pursuant to the Lending Agreement, and
BNP fails to return the Lent Securities or equivalent securities in a timely
fashion, BNP shall remain liable to the Fund’s custodian for the ultimate delivery
of such Lent Securities, or equivalent securities, and for any buy-in costs that
the executing broker for the sales transaction may impose with respect to the
failure to deliver. The Fund also has the right to apply and set-off an amount
equal to one hundred percent (100%) of the then-current fair market value of such
Lent Securities against the Current Borrowings. In addition, the Fund is a
beneficiary of an irrevocable guaranty issued by BNP’s parent, BNP Paribas, a
French banking institution that meets the definition of “eligible foreign
custodian” under Rule 17f-5 of the Investment Company Act of 1940. Under the terms
of the guaranty, BNP Paribas has agreed to guarantee the obligation of BNP to pay
to the Fund any cash or securities owed under the terms of the Lending Agreement.
The guaranty does not create any rights or grant any remedies to any person other
than the Fund and other persons who are defined as beneficiaries under the
guaranty. The Fund will exercise its set-off rights, or will exercise its rights
under the guaranty, when in accordance with its business discretion, it believes
that doing so is in the best interests of the Fund and its shareholders. The
Fund’s board of Trustees, including its independent Trustees, has determined that
the financing package is in the best interest of the Fund.

Mr. Larry Greene

February 18, 2010

Page 6

    8.

    Comment: On page 2 of the prospectus the Fund discusses Dividends and Distributions on Common
Shares. Please advise the staff supplementally whether the regular monthly dividends include
any return of capital to shareholders. In addition, please clarify the first paragraph to
note explicitly, if correct, that there were two dividends paid in January 2006 and January
2009: the regular monthly dividend and a second, special dividend.

    Response: The Fund has paid monthly distributions during the current fiscal year that were
estimated to be sourced, in part, from a return of capital, which is disclosed to
shareholders on the notice delivered in accordance with Section 19(a) of the 1940 Act.
However, distributions are subject to re-characterization for tax purposes after the end of
the fiscal year, and none of the Fund’s distributions have included a return of capital as
determined on a tax basis.

    The first paragraph of the section entitled “Dividends and Distributions on Common Shares”
on page 2 of the prospectus has been revised as follows:

    The Fund made special supplemental distributions, in addition to the
regular monthly distributions, of $0.0250 in January 2006 and of $0.0561 in
January 2009.

    9.

    Comment: In the last paragraph on page 2 of the prospectus, the Fund notes that it may pay a
portion of the dividends as a return of capital. Please advise the staff supplementally
whether there are any limits imposed on the ability of the Fund to make distributions of
capital.

    Response: As stated in the prospectus, the Fund currently intends to make monthly
distributions to common shareholders at a level rate established by the Board of Trustees.
Although there is technically no limit on the portion of those distributions that may be
sourced from a return of capital, the Fund first looks to net investment income and net
realized short-term capital gains to maintain a level distribution rate. To date, the Fund
has not “returned capital” as determined on a tax basis during any calendar year.

    10.

    Comment: The last sentence of the first full paragraph on page 4 of the prospectus (“In
addition, it is not contemplated....”) appears to indicate that the level distribution policy will
continue unchanged if the Fund