SecProbe.io

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								February 10, 2005

Andrew B. Kopans, Esq.
Skadden, Arps, Slate, Meagher & Flom LLP
One Beacon Street
Boston, MA  02108-3194

      RE:	Gabelli Global Gold, Natural Resources & Income Trust
      333-121998; 811-21698
Dear Mr. Kopans:

	We have reviewed the registration statement on Form N-2 for
the
Gabelli Global Gold, Natural Resources & Income Trust, filed with
the
Securities and Exchange Commission on January 12, 2005.  We have
the
following comments:

PROSPECTUS

1. Please note that a comment given in one section also should be
complied with throughout the registration statement.

Cover Page
2. On the cover page, it states that "the Fund`s primary
investment
objective is to provide a high level of current income."  In the
"Investment Policies and Strategy" section, it states that "the
Fund
intends to earn income through an option strategy of writing
(selling) covered call options."  Please explain supplementally
how
the Fund intends to meet its objective of earning a high level of
income with option premiums (e.g. without a commitment to invest
in
income-producing securities).

3. In the "Investment Policies and Strategy" section on the cover
page, in the prospectus summary, in the SAI, and elsewhere as
appropriate, please remove the words "anticipates that it" in the
statements relating to the Fund`s concentration policy of
investing
at least 25% of its assets in each of the Gold and Natural
Resources
Industries.

4. In the "Investment Policies and Strategy" section, it states
that
"the Fund may invest in the securities of companies located
anywhere
in the world."  Please expand the disclosure to evidence a greater
commitment to invest "Globally" (i.e. in a minimum number of
countries and a minimum % of net assets).

Prospectus Summary
5. Under the heading "Investment Objective and Policies" it states
that, "Principally engaged, as used in this prospectus, means a
company that derives a substantial portion of its income or
devotes a
substantial portion of its assets to the indicated businesses."
Please define "substantial portion" (e.g. the company earns at
least
50% of its revenues from the indicated industry and/or the company
invests at least 50% of its assets in the indicated industry).

6. In the Prospectus Summary under the heading "Investment
Objective
and Policies," it states that "the Investment Adviser`s investment
philosophy with respect to selecting investments in the gold
industries and the natural resources industries is to emphasize
quality and value."  Please disclose how this strategy will be
measured as well as the criteria used by the Investment Adviser.

7. On page 3 under the heading "Market Price of Shares" it states
that "the Fund`s net asset value per share will be reduced
immediately following the offering of common shares by the amount
of
the sales load and organization and offering expenses paid by the
Fund."  Please remove "organization and" because the Fund will not
pay the organization expenses.  In addition, on pages 36 and 42
under
the headings "Description of the Shares" and "Underwriting,"
please
ensure that the Fund will not pay organization expenses.

8. On page 7 under the heading "Emerging Markets Risk," please
define
"Emerging Markets."  In addition, include the strategy of
investing
in Emerging Markets securities under the heading "Investment
Objective and Policies."

9. On page 12 under the heading "Lower Grade Securities," it
states
that "the Fund may invest no more than 10% of its assets in fixed
income securities rated in the lower rating categories of
recognized
statistical rating agencies or unrated securities of comparable
quality, and an unlimited percentage of its assets in convertible
bonds of such quality."  Please disclose the lowest acceptable
rating
of securities in which the Fund may invest.  Also, since the Fund
may
invest in an unlimited percentage in lower grade convertible
securities, please provide the appropriate disclosure for "Junk
Bonds."

Fee Table
10. On page 14 in the Fee Table and under the heading "Use of
Proceeds," please remove the statements indicating that the Fund
will
pay organizational expenses.  The Fund`s Investment Adviser will
pay
the Organizational Expenses for this offering.

Investment Objective and Policies
11. On page 18 under the heading "Options", please disclose the
Fund`s current intention (if any) of purchasing or selling
(writing)
options that are not "covered".  Is there a limit to selling
(writing) options that are not "covered"?

12. On page 20 under the heading "Short Sales", it states that
"the
Fund may also make short sales against the box without respect to
such limitations."  Please disclose the limitations (none are
mentioned in the paragraph).

Dividends and Distributions
13. On page 35 it states, "As the Fund is covered by an exemption
from the 1940 Act which allows the Board to implement a level
dividend policy, the Board in the future may determine to cause
the
Fund to distribute a fixed percentage of the Fund`s average net
asset
value over a specified period of time or market price per common
share at or about the time of distribution or pay-out of a fixed
dollar amount."  Please disclose the potential consequences to
shareholders as a result of such distribution policies.  In
addition,
the disclosure in the Prospectus Summary under the caption
"Dividends
and Distributions" should be consistent with the disclosure in
this
section.

Automatic Dividend Reinvestment and Voluntary Cash Purchase Plan
14. On page 36 it states that "experience under the Plan may
indicate
that changes are desirable."  Please disclose the circumstances
and
conditions when such changes will be made.

Net Asset Value
15. On page 39 it states that "the Fund may employ recognized
pricing
services from time to time for the purpose of pricing portfolio
instruments."  Please make it clear that such pricing services
will
be subject to procedures approved by the Board of Directors.

Forward-Looking Statements
16. On page 45, the section titled "Special Note Regarding
Forward-
Looking Statements" attempts to limit liability for forward-
looking
statements.  Please delete this section.  Statements relating to
investment companies and statements made in connection with
initial
public offerings are excluded from the safe harbor for forward-
looking statements.  See Section 21E(b)(2)(B) & (D) of the
Securities
Exchange Act of 1934.

STATEMENT OF ADDITIONAL INFORMATION

Investment Restrictions
17. On page B-12 please state in (1) that the Fund will invest at
least 25% of its net assets in Gold Companies and at least 25% of
its
net assets in Natural Resources Companies.

18. On page B-12 please state in (4) that the Fund may lend
portfolio
assets up to 20% of the Fund`s total assets.

Management of the Fund
19. On page B-15 it states that "securities purchased or sold
pursuant to contemporaneous orders entered on behalf of the
investment company accounts of the Investment Adviser or the
investment advisory accounts managed by its affiliates for their
unaffiliated clients are allocated pursuant to principles believed
to
be fair and not disadvantageous to any such accounts."  Please
disclose whether the allocation procedures have been approved by
the
Fund`s board of directors.

20. On page B-15 it states that the advisory fee "will be reduced
each year following the fifth anniversary of the Investment
Advisory
Agreement by ( ) basis points until the eighth anniversary, after
which time the Investment Adviser will be compensated at an annual
rate of ( )% of the Fund`s average weekly total assets."  Please
include this information in a pre-effective amendment.

Dividends and Distributions
21. On page B-16 it states that the Fund "is covered by an
exemption
from Section 19(b) of the 1940 Act and Rule 19b-1 thereunder
permitting the Fund to make periodic distributions of long-term
capital gains provided that any distribution policy of the Fund
with
respect to its common shares calls for periodic distributions in
an
amount equal to a fixed percentage of the Fund`s average net asset
value over a specified period of time or market price per common
share at or about the time of distribution or pay-out of a fixed
dollar amount."  Please disclose the consequences to the
shareholders
of this distribution policy.  In addition, please verify that
notifications to shareholders pursuant to Rule 19a-1 of the 1940
Act
will clearly indicate what portion of each distribution is from
net
income, net gains, and return of capital.

GENERAL

22. We note that portions of the filing are incomplete.  We may
have
additional comments on such portions when you complete them in a
pre-
effective amendment, on disclosures made in response to this
letter,
on information supplied supplementally, or on exhibits added in
any
pre-effective amendments.

23. If you intend to omit certain information from the form of
prospectus included with the registration statement that is
declared
effective in reliance on Rule 430A under the Securities Act,
please
identify the omitted information to us supplementally, preferably
before filing the Trust`s final pre-effective amendment.

24. Please advise us if you have submitted or expect to submit an
exemptive application or no-action request in connection with your
registration statement.

25. Response to this letter should be in the form of a pre-
effective
amendment filed pursuant to Rule 472 of the Securities Act.  Where
no
change will be made in the filing in response to a comment, please
indicate this fact in a supplemental letter and briefly state the
basis for your position.

TANDY LETTER

   We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the Fund and its management are in
possession of all facts relating to the Fund`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

   Notwithstanding our comments, please furnish a letter
acknowledging that
* Should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* The action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* The Fund may not assert this action as defense in any proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Investment Management in connection with our review of
your filing or in response to our comments on your filing.

   We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.

			*		*		*		*

		If you have any questions about these comments, please
call
me at 202-551-6957.

								Sincerely,

								Laura E. Hatch
								Staff Accountant

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