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September 27, 2022

VIA EDGAR

Mr. Chad Eskildsen

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Ms. Ashley Vroman-Lee

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re:          Response to Comments on the proxy statements/prospectuses filed on Form N-14 (each, a “Proxy Statement/Prospectus” and collectively, “Proxy Statement/Prospectus”) by the following funds (each an “Acquiring Fund” and, collectively the “Acquiring Funds”) on August 11, 2022:

abrdn Global Dynamic Dividend Fund

Securities Act File No. 333-266796

abrdn Global Infrastructure Income Fund

Securities Act File No. 333-266798

abrdn Income Credit Strategies Fund

Securities Act File No. 333-266799

Mr. Eskildsen and Ms. Vroman-Lee:

This letter responds to comments on the Proxy Statements/Prospectuses with respect to the proposed reorganizations as shown below that the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) provided via email to Thomas Bogle of Dechert LLP on August 24, 2022, and via telephone conversation with Ashley Vroman-Lee and Thomas Bogle of Dechert LLP on September 2, 2022.

Acquired Funds (each an “Acquired Fund”)

Acquiring Funds

Delaware Enhanced Global Dividend and Income Fund

into

abrdn Global Dynamic Dividend Fund

Delaware Investments® Dividend and Income Fund, Inc.

Macquarie Global Infrastructure Income Fund, Inc.

into

abrdn Global Infrastructure Income Fund

Delaware Ivy High Income Opportunities Fund

into

abrdn Income Credit Strategies Fund

On behalf of the Acquiring Funds, your comments and our responses to them are provided below. All defined terms in this letter have the same meaning as in the Proxy Statements/Prospectuses, except as defined herein.

Comments provided on August 24, 2022

Comment applicable to each Proxy Statement/Prospectus

Comment 1:                 With respect to the following question and answer in the Questions and Answers Section of each Proxy Statement/Prospectus: “Will there be any significant portfolio transitioning in connection with the Reorganization?” — the Staff notes that a significant portion of the Acquired Funds’ respective portfolios will be sold prior to and/or after the reorganizations. Related to these sales, please disclose the following information with respect to each Acquired Fund:

1. Estimated per share and dollar amount of transaction expenses.

2. Estimated per share and dollar amount of realized capital gains.

Response:                             The Proxy Statements/Prospectuses have been revised to reflect the Staff’s comment.

Comment applicable to abrdn Income Credit Strategies Fund and abrdn Global Dynamic Dividend Fund

Comment 2:                 Please explain why the impact of the difference in valuation methods for certain debt holdings disclosed in the Questions and Answers Section in the following question: “How will the reorganization affect the value of my investment?” is not reflected as an adjustment on the Capitalization table.

Response:                     The Proxy Statements/Prospectuses have been revised to reflect the Staff’s comment and the capitalization tables for each of the abrdn Income Credit Strategies Fund and the abrdn Global Dynamic Dividend Fund have been replaced with the following:

abrdn Income Credit Strategies Fund:

Capitalization

The table below sets forth the capitalization of the Acquired Fund and the Acquiring Fund as of August 31, 2022, and the pro forma capitalization of the Combined Fund as if the Reorganization had occurred on that date. As shown below, it is anticipated that the NAV of Acquiring Fund shareholders’ shares would decrease due to the valuation differences described in this Proxy Statement/Prospectus and Acquiring Fund assets would increase.

Acquired Fund

Acquiring Fund

Adjustments

Pro Forma
   Combined Fund

Net   Assets (all classes)

$

198,827,167

$

183,113,336

$

(707,549

)(a)

$

381,232,954

Common   Shares Outstanding(b)

16,570,000

24,798,966

10,371,350

(c)

51,740,316

NAV Per   Common Share

$

12.00

$

7.38

$

(12.01

)(a)(c)

$

7.37

Preferred   Shares Outstanding

None

1,600,000

None

1,600,000

Liquidation   Preference per Preferred Share

None

$

25

None

$

25

(a)

For purposes of determining the Acquired Fund’s   net asset value, corporate, municipal, and convertible fixed income   securities as well as bank loan agreements are priced at the mean of   evaluated bid and asked prices provided by third-party pricing vendors on the   valuation date. In contrast, the Acquiring Fund values such securities at the   bid price provided by third-party pricing vendors.

(b)

Based on the number of outstanding common shares   as of August 31, 2022.

(c)

Reflects the conversion of Acquired Fund shares   for Acquiring Fund shares as a result of the Reorganization.

abrdn Global Dynamic Dividend Fund:

Capitalization

The tables below set forth the capitalization of each Acquired Fund and the Acquiring Fund as of August 31, 2022, and the pro forma capitalization of the Combined Fund as if the Reorganizations had occurred on that date. As shown below, it is anticipated that the NAV of Acquiring Fund shareholders’ shares would decrease (or remain the same in the case of the DDF into the Acquiring Fund only Reorganization) due to the valuation differences described in this Proxy Statement/Prospectus and Acquiring Fund assets would increase.

DEX into the Acquiring Fund only

DEX

Acquiring
   Fund

Adjustments

Pro Forma
   Combined Fund (DEX
   into the Acquiring Fund
   only)

Net   Assets

$

91,261,254

$

132,710,491

$

(190,558

)(a)

$

223,781,187

Common   Shares Outstanding(b)

10,620,970.68

12,549,581.97

(1,986,982.60

)(c)

21,183,570.05

NAV Per   Common Share

$

8.59

$

10.57

$

(8.60

)(a)(c)

$

10.56

DDF into the Acquiring Fund only

DDF

Acquiring
   Fund

Adjustments

Pro Forma
   Combined Fund
   (DDF into the
   Acquiring Fund only)

Net   Assets

$

68,815,020

$

132,710,491

$

(71,978

)(a)

$

201,453,533

Common   Shares Outstanding(b)

7,611,158.16

12,549,581.97

(1,100,749.46

)(c)

19,059,990.67

NAV Per   Common Share

$

9.04

$

10.57

$

(9.04

)(a)(c)

$

10.57

DEX and DDF into the Acquiring Fund

DEX

DDF

Acquiring
   Fund

Adjustments

Pro Forma
   Combined Fund
   (DEX and DDF
   into the
   Acquiring
   Fund)

Net   Assets

$

91,261,254

$

68,815,020

$

132,710,491

$

(262,536

)(a)

$

292,524,229

Common   Shares Outstanding(b)

10,620,970.68

7,611,158.16

12,549,581.97

(3,087,732.06

)(c)

27,693,978.75

NAV Per   Common Share

$

8.59

$

9.04

$

10.57

$

(17.64

)(a)(c)

$

10.56

(a)

For purposes of   determining an Acquired Fund’s NAV, corporate, sovereign, and convertible   fixed income securities are priced at the mean of evaluated bid and asked   prices provided by third-party pricing vendors on the valuation date. In   contrast, the Acquiring Fund values such securities at the bid price provided   by third-party pricing vendors.

(b)

Based on the number of   outstanding common shares as of August 31, 2022.

(c)

Reflects the conversion   of Acquired Fund shares for Acquiring Fund shares as a result of the   Reorganizations.

Comment applicable to abrdn Income Credit Strategies Fund and abrdn Global Infrastructure Income Fund

Comment 3:                 The Staff notes that a significant portion of the Acquiring Funds’ respective portfolios will be sold either before or after the reorganizations. Regarding the statements of additional information (“SAIs”) filed for the abrdn Income Credit Strategies Fund and the abrdn Global Infrastructure Income Fund, please explain why a schedule of investments identifying the securities of the respective Acquired Fund to be sold is not included in the registration statement. The Staff notes that adjusted schedules of investments of the relevant Acquired Funds were included in the abrdn Global Dynamic Dividend Fund SAI.

Response:                     The Registrants determined that a schedule of investments of the relevant Acquired Fund identifying the securities to be sold was not necessary for the abrdn Income Credit Strategies Fund and the abrdn Global Infrastructure Income Fund SAIs. Specifically, the reorganizations for the abrdn Income Credit Strategies Fund and the abrdn Global Infrastructure Income Fund will not result in material changes to the respective Acquired Fund’s investment portfolio due to the investment restrictions of the relevant Acquiring Fund, since substantially all of the securities held by the respective Acquired Fund are eligible to be held by the Acquiring Fund. As a result, a schedule of investments of the Acquired Fund modified to show the effects of the change is not required and is not included for either of the abrdn Income Credit Strategies Fund or the abrdn Global Infrastructure Income Fund.

The reorganization for the abrdn Global Dynamic Dividend Fund will result in material changes to each Acquired Fund’s investment portfolio due to the investment restrictions of the Acquiring Fund because portions of the portfolios of each respective Acquired Fund are not eligible to be held by the Acquiring Fund. For example, DDF invests at least 65% of its total assets in equity securities, while the Acquiring Fund invests at least 80% of its net assets in such securities. Additionally, DDF may also invest up to 35% of its total assets in non-convertible debt securities, while the Acquiring Fund may invest up to 20% of its net assets in such securities. For this reason, an annotated schedule of investments for each Acquired Fund is required to be included in the abrdn Global Dynamic Dividend Fund SAI. The annotated schedule of investments reflects all of the changes anticipated to be made pre- and post-reorganization. With respect to the abrdn Global Dynamic Dividend Fund, the Registrant determined that approximately 30% of DDF’s holdings and approximately 30% of DEX’s holdings are anticipated to be sold by each Acquired Fund before the closing of the Reorganization in order to pay back each Acquired Fund’s outstanding leverage. Based on the holdings as of May 31, 2022, the Combined Fund expects to sell approximately 65% and 68% of each Acquired Fund’s portfolio, respectively, following the closing of the Reorganizations.

Comment applicable to the abrdn Global Infrastructure Income Fund only

Comment 4:                 Please supplementally provide an analysis supporting the determination of the abrdn Global Infrastructure Income Fund as the accounting survivor with respect to the reorganization with the Macquarie Global Infrastructure Total Return Fund Inc. Please refer to the North American Security Trust, SEC No-Action Letter (pub. avail. Aug. 5, 1994) (“NAST Letter”).

Response:                     The Registrant has supplementally provided the analysis supporting the determination of the Acquiring Fund as the accounting survivor, attached as exhibit A.

Comments provided on September 2, 2022

Comments applicable to each Proxy Statement/Prospectus

Comment 1:                 Please incorporate all comments previously provided with respect to the Preliminary Schedule 14A filings filed on August 19, 2022 for the abrdn Income Credit Strategies Fund, abrdn Global Dynamic Dividend Fund and abrdn Global Infrastructure Income Fund into the Proxy Statements/Prospectuses, as appropriate.

Response:                     The Proxy Statements/Prospectuses have been revised accordingly.

Comment 2:                 The Proxy Statements/Prospectuses contain the following disclosure: “It is expected that shareholders of the Acquired Fund(s) will not recognize any gain or loss for federal income tax purposes as a result of the exchange of their shares in the Acquired Fund(s) for shares of the Acquiring Fund pursuant to the Reorganization Agreement (except with respect to cash received in lieu of fractional shares).” Please add disclosure to address any expected taxable gains or losses associated with the repositioning of the Acquired Fund(s) in connection with the reorganizations (or indicate that the repositioning is not expected to result in any significant capital gains/losses).

Response:                     The Proxy Statements/Prospectuses have been revised accordingly.

Comment 3:                 With respect to the subsection entitled “Board Consideration of the Reorganization(s)” within the Background and Reasons for the Proposed Reorganization(s) section of the Proxy Statements/Prospectuses, please include any negative considerations from the boards, if any — that is, any factors considered that argued against approving the reorganizations.  Please include balanced disclosure or disclosure that reflects pros and cons weighed by the boards, if any. Also, pursuant to for N-14, please provide a brief explanation of how the boards considered and applied these factors.

Response:                     The Acquiring Funds believe that the Board Considerations discussion fairly describes the factors that the Boards weighed. None of the matters considered by the Boards is characterized as being positive or negative.  The Boards considered details regarding the matters disclosed and concluded, based on the totality of the information as to all factors, to recommend the reorganizations to shareholders.  The Acquiring Funds respectfully decline to add additional language as such disclosure is not required by Form N-14.

Comment 4:                 The Proxy Statements/Prospectuses contain a section discussing the possibility of converting to an open-end fund. Please explain the rationale for this disclosure. Are the Acquiring Funds planning to convert to open-end funds at a later date?

Response:                     The Acquiring Funds’ registration statements and organizational documents provide for a process for the Acquiring Funds to convert from a closed-end fund structure to an open-end fund structure, and such disclosure is included in the respective Proxy Statements/Prospectuses. However, conversion to an open-end fund structure for any of the Acquiring Funds is extremely unlikely in light of each Acquiring Fund’s investment objective and policies and would require the approval of each Acquiring Fund’s board and shareholders. The Acquiring Funds have no plans to convert to an open-end fund structure.

*                    *                     *                     *                    *

Should you have any questions concerning the above, please call the undersigned at (202) 261-3360.

Very truly yours,

/s/ Thomas C. Bogle

Thomas C. Bogle

Appendix A

This Appendix A provides supplemental information regarding the Reorganization and, in particular, the proposed accounting survivor of the Reorganization under the factors set forth in the NAST Letter. For the reasons set forth below, we believe that the Acquiring Fund has been properly designated as the accounting survivor in a manner consistent with the application of the NAST Letter factors. For the purposes of this letter, the Acquiring Fund, as it would exist after the completion of the Reorganization, is referred to as the “Combined Fund.”

The NAST Letter

The NAST Letter sets forth the factors that the SEC staff (the “Staff”) believes are relevant to the continuation of a performance record in a reorganization transaction, and it has also been applied more generally to an analysis of the accounting survivor in a fund reorganization. The standards articulated by the Staff in the NAST Letter are as follows:

In determining whether a surviving fund, or a new fund resulting from a reorganization, may use the historical performance of one of several predecessor funds, funds should compare the attributes of the surviving or new fund and the predecessor funds to determine which predecessor fund, if any, the