SecProbe.io

CORRESP
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  1900
                                            K Street, N.W.

                                            Washington, DC 20006-1110

+1 202 261 3300 Main

+1 202 261 3333 Fax

www.dechert.com

November 9, 2023 Mary
                                            Anne Morgan

MaryAnne.Morgan@dechert.com

+1 202 261 3473 Direct

+1 202 261 3333 Fax

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attention: Ms. Christina
DiAngelo Fettig

Re: Virtus Stone Harbor Emerging
Markets Income Fund (the “Registrant”)

(File No. 333-271026)

Dear Ms. DiAngelo Fettig:

This letter responds to the comments you provided
to me in a telephonic discussion on November 8, 2023 with respect to your review of the Registrant’s amended preliminary Registration
Statement filed on Form N-14 under the Securities Act of 1933, as amended, on November 7, 2023 (the “Registration Statement”).
We have reproduced your comments below, followed by the Registrant’s responses. Capitalized terms have the meanings attributed
to such terms in the Registration Statement.

Accounting Comments

    Comment 1.
    The Staff notes that the Fees and Expenses Table was
    updated to reflect data as of May 31, 2023. Please confirm that the fees reflected in the table represent current fees as required
    by Form N-14, Item 3.

    Response 1.
    The Registrant confirms that the fees and expenses reflected
    in the Fees and Expenses Table of the Registration Statement represent current fees as required by Form N-14, Item 3.

    Comment
    2.
    Please confirm
    that there have been no material changes to the capitalization of the Acquired Fund, Acquiring Fund and pro forma Combined Fund since
    May 31, 2023.

    Response
    2.
    The
    Registrant confirms that there have been no material changes to the capitalization of the Acquired Fund, Acquiring Fund and pro forma
    Combined Fund since May 31, 2023.

    Comment 3.
    Please include hyperlinks to the May 31, 2023
    Semiannual Reports referenced in the Registration Statement.

    Response 3.
    The Registrant has revised the Registration Statement accordingly.

    Comment 4.
    The Staff notes that the net assets presented for
    the Acquired Fund and Acquiring Fund differed from their respective May 31, 2023 Semiannual Reports. Please explain the differences
    in correspondence.

    Response 4.
    The Registrant has incorporated this comment into its Registration
    Statement as follows:

Capitalization

The table below sets forth
the capitalization of the Acquired Fund and the Acquiring Fund as of May 31, 2023, and the pro forma capitalization of the
Combined Fund as if the Reorganization had occurred on that date.

    Acquired

 Fund
    Acquiring
    Fund
    Adjustments
    Pro Forma

 Combined Fund

    Net Assets
    $ 47,430,395

 47,433,000

    $ 68,675,118

 68,674,000

    (450,000 )(1)
    $
    115,655,513

                                                                                115,657,000

    Common Shares Outstanding
      10,019,162
      17,232,116    1,882,180

 1,883,028

    $ 29,133,457

 29,134,306

    Net Asset Value Per Share
    $ 4.73
    $ 3.99
    -
    $
    3.97

​​(1) The
expenses of the Reorganization are estimated to be $450,000.

    Comment
    5.
    In the Questions
    and Answers section of the Registration Statement, the Registrant states: “It is anticipated that there will be no significant
    portfolio transitioning in connection with the Reorganization.” Please explain and describe the extent to which the Registrant
    anticipates portfolio repositioning.

    Response
    5.
    The Registrant confirms that
    it does not anticipate any repositioning. Any repositioning would be de minimis in nature.

*       *       *

We believe that the foregoing has been responsive
to the Staff’s comments. Please call the undersigned at (202) 261-3473 if you wish to discuss this correspondence further.

    Very truly yours,

    /s/ Mary Anne
    Morgan

    Mary Anne Morgan