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willburns@paulhastings.com

December 22, 2021

VIA EDGAR CORRESPONDENCE FILING

Ms. Ashley Vroman-Lee

Mr. Jason Fox

Division of Investment Management,

   Disclosure Review Office

United States Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549-8626

 Re: Kayne Anderson Energy Infrastructure Fund, Inc.

Registration Statement on Form N-14 (File No. 333-260457)

Dear Ms. Vroman-Lee and Mr. Fox:

This letter relates to the Registration Statement
on Form N-14 (the “Registration Statement”) of our client, Kayne Anderson Energy Infrastructure Fund, Inc. (“KYN”
or the “Registrant”), filed with the U.S. Securities and Exchange Commission (the “Commission”)
on October 25, 2021 pursuant to the Securities Act of 1933, as amended. This letter is being filed in response to oral comments given
on November 22, 2021 by Ashley Vroman-Lee and on November 24, 2021 by Jason Fox of the staff of the Commission (the “Staff”).

Concurrently with the submission of this letter,
we are filing through EDGAR Amendment No. 1 to the Registration Statement (“Amendment No. 1”). For your convenience,
we will send to you by email a marked copy of the Registration Statement showing changes made.

Each response is prefaced by the Staff’s
corresponding comment in italicized text. Unless otherwise specified, page references in the text of this response letter correspond to
the page numbers in Amendment No. 1. All capitalized terms not otherwise defined herein shall have the meaning set forth in Amendment
No. 1. The Registrant acknowledges the Staff’s standard disclaimer that the Registrant remains responsible for its disclosure in
the Registration Statement.

GENERAL

 1. Please provide additional information, including filling any missing information in the Registration Statement, in a future amendment
filing.

Response:

KYN acknowledges the Staff’s comment and has provided
the required missing information in Amendment No. 1.

Ms. Ashley Vroman-Lee
 Mr. Jason Fox
 U.S. Securities and Exchange Commission
 December 22, 2021
 Page 2

 2. Where applicable, disclose in the Registration Statement which Company will be the accounting survivor following the Merger.

Response:

KYN acknowledges the Staff’s comment and has revised
Amendment No. 1 to clarify that KYN will be the accounting survivor following the Merger, as reflected on pages 7, 42, 86 and SAI-1.

 3. Where applicable, including in the Question and Answer section, please include relevant disclosure in the Registration Statement
relating to FMO’s tax accruals for estimated federal and state income tax expenses resulting from the application of income tax
recapture rules to FMO’s sales of MLP energy infrastructure investments during fiscal year 2020 (the “Tax Accrual Matter”).
In particular, please note that the Tax Accrual Matter resulted in an error in FMO’s net asset value (“NAV”) and necessitated
a restated and re-issued semi-annual report from FMO.

Response:

KYN acknowledges the Staff’s comment and has revised
Amendment No. 1 to reflect the comments relating to the Tax Accrual Matter and FMO’s voluntary shareholder compensation program
where deemed appropriate (please see disclosures and response to Staff Comment 5).

 4. Where applicable, please include additional disclosure about FMO’s operations and relationships that would be meaningful
for shareholders.

Response:

KYN acknowledges the Staff’s comment and has revised
Amendment No. 1 to reflect the following additional disclosure, as reflected on page 60:

Additional Service Providers

MUFG Investor Services (US) (“MUFG”)
serves as FMO’s administrator. MUFG is located at 805 King Farm Boulevard, Rockville, Maryland 20850. Pursuant to an administration
agreement with FMO, MUFG provides certain administrative, bookkeeping and accounting services to FMO. MUFG also provides certain fund
accounting services to FMO pursuant to a fund accounting agreement.

The Bank of New York Mellon Corp. serves
as FMO’s custodian.

Ms. Ashley Vroman-Lee
 Mr. Jason Fox
 U.S. Securities and Exchange Commission
 December 22, 2021
 Page 3

 5. Please include a discussion of FMO’s voluntary shareholder compensation program in the Registration Statement.

Response:

KYN acknowledges the Staff’s comment and has revised
Amendment No. 1 to reflect the following additional disclosure, as reflected on pages 5 and 94:

Q: What impact will the Merger have on FMO’s existing shareholder
compensation program?

A: A shareholder compensation
program was previously established by FMO’s investment adviser, GFIA, to compensate FMO investors who purchased or sold shares between
March 9, 2020 and February 1, 2021 and may have been adversely affected by the timing of the disclosure and accrual of certain tax adjustments
to FMO’s portfolio. GFIA will continue the administration of the shareholder compensation program, which will not be affected
by the Merger. Neither FMO nor KYN will bear the cost of the compensation payable under this program. For more information, including
regarding FMO’s tax accruals, please see “Proposal: Merger—Shareholder Compensation Program Information.”

Shareholder Compensation Program Information

As previously disclosed by FMO, on November 13, 2020, in connection
with the sale of MLP interests, and the determination to estimate FMO’s tax expense related to ordinary income from recapture in
closer proximity to the sale of such MLP Investments, FMO reflected in its NAV an accrual of estimated tax liability for the tax expense
related to the sale of certain of its MLP investments. Following further review, FMO determined, on December 28, 2020, it was appropriate
to adjust the accrual by allocating and recording a portion of the accrual in connection with each sale of a MLP Investment by FMO beginning
as of March 6, 2020. FMO also reviewed its application of the income tax recapture rules in prior years and the effect of such applications
on prior years’ financial statements and tax return filings. Upon the conclusion of its review, FMO determined, on February 1, 2021,
that no adjustment was required for any year prior to the fiscal year ended November 30, 2020, and that it was appropriate to reduce the
estimated tax liability that was accounted and recorded on November 13, 2020, to reflect certain reclassifications of income and related
changes in FMO’s tax liabilities beginning as of March 6, 2020. FMO then re-stated its NAV to reflect the accruals recorded during
the time period beginning March 6, 2020. FMO’s investment adviser also reimbursed FMO for excess asset-based fees paid to FMO’s
service providers as a result of the overstatement of FMO’s NAV during the relevant period, beginning on March 6, 2020. As a result,
FMO previously restated its Statement of Assets and Liabilities as of May 31, 2020, the interim financial reporting period, and its Statement
of Operations for the period then ended, its Statements of Changes in Net Assets and Statement of Cash Flows for the period ended May
31, 2020, and its Financial Highlights for the period ended May 31, 2020.

In recognition that certain of FMO’s shareholders may have been
adversely affected by these events, FMO’s investment adviser initiated a Shareholder Compensation Program to compensate FMO investors
who suffered cognizable losses, as determined under applicable law, in connection with the timing of the accruals related to the sale
of its MLP Investments during the relevant time period. The Shareholder Compensation Program compensates FMO investors who purchased or
sold shares between March 9, 2020 and February 1, 2021 and may have been adversely affected by these events. FMO is not bearing the cost
of compensating such investors, or the administration of that program, nor is it bearing certain expenses incurred in connection with
the review of FMO’s past accrual practices because FMO’s investment adviser is compensating eligible investors directly. The
administration of the Shareholder Compensation Program, which remains underway, will not be affected by the Merger. Neither FMO nor KYN
will bear the cost of the compensation payable under this program and the eligible FMO investors’ ability to be compensated is not
affected by the Merger.

Ms. Ashley Vroman-Lee
 Mr. Jason Fox
 U.S. Securities and Exchange Commission
 December 22, 2021
 Page 4

 6. For purposes of clarity, consider using “Acquirer” and “Target” labels for KYN and FMO, respectively, where
appropriate throughout the Registration Statement, and in addition to the terms “KYN” and “FMO”.

Response:

KYN acknowledges the Staff’s comment
and has revised Amendment No. 1 to include clarifying references to KYN as the “Acquirer” and FMO as the “Target”
where appropriate, as reflected on pages 2, 8, 12, 13, 43, 44, 53, 54, 55, 61, 76, 77, 78, 80 and 85.

 7. Please confirm in your correspondence to us that there will be no portfolio repositioning as a result of the Merger.

Response:

KYN acknowledges the Staff’s comment
and confirms that no material portfolio repositioning as a result of the Merger is planned or contemplated.

LETTER TO SHAREHOLDERS

 8. In the second paragraph of the letter to shareholders, clarify that the shareholders are being asked to approve (and not authorize)
the Merger.

Response:

KYN acknowledges the Staff’s comment and has revised
the letter to shareholders in Amendment No. 1 to reflect the following revised disclosure:

At the Meeting, FMO shareholders will be
asked to consider and approve the combination of FMO and KYN, which will be accomplished as a tax-free merger of FMO into KYN (the “Merger”),
and any adjournment or postponement of the Meeting.

Ms. Ashley Vroman-Lee
 Mr. Jason Fox
 U.S. Securities and Exchange Commission
 December 22, 2021
 Page 5

JOINT PROXY STATEMENT/PROSPECTUS

 Cover

 9. Please prominently disclose that fees borne by FMO shareholders will increase as a result of the Merger.

Response:

KYN acknowledges the Staff’s comment and has revised
the cover of Amendment No. 1 to include the following disclosure:

Please refer to the discussion of the proposal
in this joint proxy statement/prospectus for information regarding votes required for the approval of the Merger, as well as information
regarding the increase in fees and expenses borne by FMO shareholders as a result of the Merger as described under “Questions and
Answers—What are some of the key factors that the FMO Board of Trustees considered in determining that the Merger is in the best
interests of FMO’s shareholders?—The potential benefits of the Merger outweigh the expected higher fees and expenses that
will be borne by FMO shareholders as a result of the Merger.”

Questions and Answers, page 1

 10. Please include a discussion of FMO’s voluntary shareholder compensation program in the Registration Statement.

Response:

KYN acknowledges the Staff’s comment and refers the
Staff to KYN’s response to Staff Comment 5.

 11. Please include a question and answer relating to any prior regulatory issues relating to FMO. In the alternative, please let us
know if there are no such issues to disclose.

Response:

KYN acknowledges the Staff’s comment and has revised
Amendment No. 1 to include additional disclosure regarding the Tax Accrual Matters in connection with its additional Registration Statement
disclosure regarding the shareholder compensation program, as reflected in the response to Staff Comment 3. Further, KYN confirms that
there are no other such issues relevant to FMO to be disclosed.

 12. Please include a prominently placed question and answer disclosing that the fees borne by FMO shareholders will increase as a result
of the Merger.

Response:

KYN acknowledges the Staff’s comment and has revised
Amendment No. 1 to highlight the increase in fees borne by FMO shareholders and clarify certain related matters, as reflected on pages
3, 9 and 44:

The potential benefits of the Merger
outweigh the expected higher fees and expenses that will be borne by FMO shareholders as a result of the Merger

Ms. Ashley Vroman-Lee
 Mr. Jason Fox
 U.S. Securities and Exchange Commission
 December 22, 2021
 Page 6

In making its determination to approve the Merger, the FMO Board of
Trustees considered the increase in total annual expenses as a percentage of net assets. While expenses as a percentage of net asset value
are higher for KYN relative to FMO, the FMO Board of Trustees considered that KYN’s performance, inclusive of such expenses, has
exceeded that of FMO for the prior 3-year, 5-year, 10-year and 15-year periods. Overall, the FMO Board of Trustees believes that the potential
benefits of the Merger outweigh the expected increase in expenses being borne by FMO shareholders. In addition to the outperformance discussed
above, those potential benefits include, among others, the larger asset base of KYN as compared to FMO, KYN’s greater potential
long-term viability as an investment vehicle, KYN’s greater potential for better long-term economies of scale for operating expenses,
the potential opportunity for enhanced market liquidity over the long term and the ability of FMO shareholders to gain exposure to a broader
range of Energy Infrastructure Companies (as defined below).

The increase in total expenses as a percentage of net assets for FMO’s
shareholders is primarily the result of (1) the higher investment management fee of the Combined Company relative to FMO, (2) the higher
use of leverage employed by KYN relative to FMO and the different types of leverage instruments employed by KYN and FMO (including that
KYN has historically utilized longer term leverage with fixed rates, as opposed to FMO’s use of shorter term leverage with floating
rates) and (3) higher deferred income tax expense at KYN as compared to FMO. For a more detailed presentation of expenses as a percentage
of net assets, including the specific amount of the increase, please see “Summary—Proposal: Merger—Fees and Expenses
of Common Shareholders as of May 31, 2021.”

While the total expenses that FMO shareholders will bear is increasing,
certain other operating expenses are decreasing. Each Company incurs operating expenses that are fixed (e.g., board fees, printing fees,
legal and auditing services) and operating expenses that are variable (e.g., administrative fees, custodial services and investment management
fees that are based on assets under management). As a result of the Merger, the Combined Company would eliminate the duplication of such
fixed expenses (approximately $0.4 million annually). There could also be an opportunity to reduce variable expenses as a percentage of
net assets of the Combined Company.

 13. Under the caption “—Questions Regarding the Merger—What are some of the key factors that the FMO Board of Trustees
considered in determining that the Merger is in the best interests of FMO’s shareholders?—FMO’s shareholders could benefit
from the larger asset base and market capitalization of the Combined Company,” please revise the sentence “KYN, therefore,
has greater potential to utilize a broader range of leverage instruments and greater financial flexibility.” to reflect that the
benefits are not certain. In addition, please include balanced disclosure around the fact that there is also a risk of greater loss to
the extent higher relative leverage is used.

Response:

KYN acknowledges the Staff’s comment and has revised
Amendment No. 1 to include the following updated disclosure, as reflected on pages 2, 8 and 43:

KYN, therefore, may have greater potential
to utilize a broader range of leverage instruments and greater financial flexibility. The use of leverage creates risks and involves special
considerations. See “Risk Factors — Additional Risks Related to Our Common Stock — Leverage Risk to Common Stockholders.”

KYN also may have greater potential for
better long-term economies of scale for operating expenses.

Ms. Ashley Vroman-Lee
 Mr. Jason Fox