SecProbe.io

CORRESP
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December 12, 2023

VIA EDGAR

Mr. Kenneth Ellington

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Ms. Anu Dubey

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Response to Comments on the
Proxy Statement/Prospectus (the “Proxy Statement/Prospectus”) and statement of additional information (“SAI”)
filed on Form N-14 on October 24, 2023 for abrdn Income Credit Strategies Fund (the “Acquiring Fund” or “Registrant”)
(Securities Act File No. 333-275178).

Mr. Ellington and Ms. Dubey:

This letter responds to comments on the Proxy
Statement/Prospectus and SAI with respect to the proposed reorganizations as shown below that the staff (the “Staff”) of the
Securities and Exchange Commission (the “SEC”) provided via telephone with Kenneth Ellington and Patricia Leeson and Louis
Rosenbaum of Dechert LLP on November 14, 2023 and Anu Dubey and Patricia Leeson and Louis Rosenbaum of Dechert LLP on November 15,
2023.

    Acquired Funds (each, an “Acquired Fund”)

    Acquiring Fund

    First Trust High Income Long/Short Fund
    into
    abrdn Income Credit Strategies Fund

    First Trust/abrdn Global Opportunity Income Fund

On behalf of the Acquiring Fund, your comments
and our responses thereto are provided below. All defined terms in this letter have the same meaning as in the Proxy Statement/Prospectus
and SAI, except as defined herein.

Comments provided on November 14, 2023

Comment
1: Please confirm that the fees presented in the fee table are still current pursuant to Item 3 of Form N-14.

Response:
The Registrant so confirms.

Comment
2: Please confirm any potential recoupment of previously waived expenses by the Acquiring Fund is accurately reflected
in the pro forma column of the fee table.

Response:
The Registrant so confirms.

Comment
3: Please disclose the estimated capital gain distributions, including per share amounts, that are expected to be generated
as a result of portfolio transitioning in the “Comparison of the Funds—Leverage” and “Material Federal Income
Tax Consequences of the Reorganizations” sections of the Proxy Statement/Prospectus.

Response:
The Registrant has added the following after the first paragraph in the “Comparison of the Funds—Leverage” section of
the Proxy Statement/Prospectus:

The portfolio de-levering discussed
above may result in capital gains or losses, which may have federal income tax consequences. For example, if the de-levering of FSD was
completed on September 21, 2023, it is estimated that approximately $16,821,000, or $0.505 per share, in capital losses would have
resulted from the sale of portfolio securities ahead of the Reorganization. If the de-levering of FAM was completed on September 21,
2023, it is estimated that approximately $2,261,000, or $0.223 per share, in capital losses would have resulted from the sale of portfolio
securities ahead of the Reorganization. The actual tax consequences as a result of portfolio repositioning are dependent on the
portfolio composition of each Acquired Fund at the time and market conditions.

    1

The Registrant will also add the following after
the first paragraph in the “Material Federal Income Tax Consequences of the Reorganizations—Distribution of Income and Gains”
section:

Because the portfolio transitioning to
be conducted ahead of each Reorganization is expected to produce capital losses, and each of FAM and FSD have capital loss carryforwards,
it is not currently anticipated that either FAM or FSD will have any undistributed investment company taxable income and/or net realized
capital gain to distribute.

Comment
4: Please include ten years of Financial Highlights for FSD, FAM and the Acquiring Fund.

Response:
The Registrant has revised the Financial Highlights accordingly.

Comment
5: The Staff notes that the Combined Fund expects to sell approximately 99% of FAM’s portfolio following the
closing of the reorganization. Please explain in correspondence (i) if these are either planned or forced sales and (ii) why
a schedule of investments of FAM modified to reflect the anticipated sale of a portion of the FAM’s portfolio holdings in connection
with the reorganization has not been included.

Response:
The Registrant notes that these are planned sales of FAM’s portfolio and not forced sales due to the Acquiring Fund’s
investment restrictions. The Registrant further determined that a schedule of investments of FAM was not necessary as the reorganization
of FAM into the Acquiring Fund will not result in a material change to FAM’s investment portfolio due to the investment restrictions
of the Acquiring Fund, since substantially all of the securities held by FAM are eligible to be held by the Acquiring Fund. As a result,
a schedule of investments of FAM modified to show the effects of the change is not required and is not included.

Comment
6: Please supplementally provide an analysis supporting the determination of the Acquiring Fund as the accounting
survivor with respect to the reorganizations. 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 Appendix A.

Comments provided on November 15, 2023

Comments applicable to Proxy Statement/Prospectus

Comment
1: With respect to the following question and answer in the Questions and Answers section of the Proxy Statement/Prospectus:
 “How will the fees and expenses of the Combined Fund compare to those of each Acquired Fund?”, please revise the response
to disclose gross total annual operating expense ratios, including interest expense, of each Fund, and, following the consummation of
one or both Reorganizations, the gross total annual operating expense ratio, including interest expense, of the Combined Fund. At the
Fund’s discretion, the Fund may also disclose net total annual operating expense ratios, including interest expense, of each Fund,
and, following the consummation of one or both Reorganizations, the net total annual operating expense ratio, including interest expense,
of the Combined Fund. If the Registrant does disclose net total annual operating expense ratios, please also state that the Adviser may
recoup any waived expenses.

Response:
The Registrant has revised the disclosure in response to this comment.

Comment
2: With respect to the following question and answer in the Questions and Answers section of the Proxy Statement/Prospectus:
 “How different are the Funds?”, please revise the response to reflect the disclosure under the “Background and Reasons
for the Proposed Reorganizations—Board Consideration of the Reorganizations” section of the Proxy Statement/Prospectus which
states “that the Acquiring Fund generally invests in lower rated bonds in the high yield sector as compared to FSD, while FAM invests
primarily in investment grade bonds.”

Response:
The Registrant has revised the disclosure to indicate that FAM currently holds a significant amount in investment grade bonds in response
to this comment.

    2

Comment
3: With respect to the following question and answer in the Questions and Answers section of the Proxy Statement/Prospectus:
 “How different are the Funds?”, please revise the fourth paragraph of the response to refer to “FSD” rather than
the “Fund”.

Response:
The Registrant has revised the disclosure in response to this comment.

Comment
4: With respect to the following question and answer in the Questions and Answers section of the Proxy Statement/Prospectus:
 “How different are the Funds?”, please revise the sixth paragraph of the response to refer to “FAM” rather than
the “Fund”.

Response:
The Registrant has revised the disclosure in response to this comment.

Comment
5: With respect to the following question and answer in the Questions and Answers section of the Proxy Statement/Prospectus:
 “How different are the Funds?”, please revise the sixth paragraph of the response to reflect the disclosure under the “Background
and Reasons for the Proposed Reorganizations—Board Consideration of the Reorganizations” section of the Proxy Statement/Prospectus
which states that “FAM invests primarily in emerging markets.”

Response:
The Registrant has revised the disclosure in response to this comment.

Comment
6: With respect to the following question and answer in the Questions and Answers section of the Proxy Statement/Prospectus:
 “Will there be any significant portfolio transitioning in connection with the Reorganizations?”, please confirm if such transfer
taxes are expected to be a significant amount from the following sentence of the answer: “To the extent an Acquired Fund has holdings
in France, Spain and/or Italy, such countries may impose an additional foreign transfer tax on the transfer of such securities to the
Acquiring Fund.” If such transfer taxes are expected to be a significant amount, please disclose the estimates of total costs and
per share costs of these taxes and which Fund will bear the costs.

Response:
The Registrant notes that the transfer taxes are not expected to be a significant amount. Additionally, in response:
 “These taxes are in addition to the transaction costs disclosed above and would be borne by the Combined Fund.”

Comment
7: With respect to the following question and answer in the Questions and Answers section of the Proxy Statement/Prospectus:
 “Will there be any significant portfolio transitioning in connection with the Reorganizations?”, please disclose the portfolio
repositioning costs for the Combined Fund as a percentage of the Combined Fund’s securities or assets and the estimated cost of
this transitioning in dollars.

Response:
The Registrant has revised the disclosure in response to this comment by adding the following sentences:

Based
on the FSD and FAM holdings as of September 21, 2023, the Combined Fund expects to sell approximately 99% of FAM’s portfolio
following the closing of the Reorganization. If the Reorganization of FAM only was completed on September 21, 2023, the expected
cost to sell 99% of FAM’s holdings following the closing of the Reorganization, which is estimated to equal 7.7% of the Combined
Fund’s portfolio, would be approximately $315,300 (or 0.04% of the estimated NAV of the Combined Fund as of September 21,
2023) or $0.0026 per share.

Comment
8: Under the “Proposals—Synopsis” section of the Proxy Statement/Prospectus, please disclose (i) the
portfolio transitioning transaction costs in dollars and as a percentage of each Fund’s assets to be borne by each Acquired Fund
and Combined Fund with respect to transaction costs of de-levering and portfolio repositioning of the Combined Fund and (ii) any
significant tax impact of repositioning, including an estimate of any capital gain distributions that could be triggered by the sales
of each Acquired Fund and the Combined Fund.

Response:
The Registrant has revised the disclosure in response to this comment by replacing the first three paragraphs on page 7 with
the following:

    3

Each Acquired Fund is required to pay
back its outstanding leverage in connection with the closing of the Reorganization. It is anticipated that approximately 26% of FSD’s
holdings and approximately 20% of FAM’s holdings will be sold by such Acquired Fund before the closing of the Reorganization in
order to pay back each Acquired Fund’s outstanding leverage. This portfolio transition may take a significant amount of time and
result in the Acquired Fund holding large amounts of uninvested cash. As a result, there may be times when an Acquired Fund is not pursuing
its investment objective or is not being managed consistent with its investment strategies. This may impact each Acquired Fund’s
performance. As of September 21, 2023, the expected costs to de-lever FSD’s portfolio would be approximately $405,000 (or
0.08% of FSD’s NAV as of September 21, 2023) or $0.012 per share. As of September 21, 2023, the expected costs to de-lever
FAM’s portfolio would be approximately $33,000 (or 0.04% of FAM’s NAV as of September 21, 2023) or $0.003 per share.
The foregoing estimates are subject to change depending on the composition of each Acquired Fund’s portfolio and market circumstances
at the time any sales are made.

Following
the Reorganization, the Combined Fund expects to realign its portfolio in a manner consistent with its investment strategies and policies,
which will be the same as the Acquiring Fund’s strategies and policies. The Combined Fund may not be invested consistent with its
investment strategies or the adviser’s investment approach while such realignment occurs. The realignment is anticipated to take
approximately one week, based on current market conditions and assuming that the Acquired Funds’ holdings are the same as of September 21,
2023. Sales and purchases of less liquid securities could take longer. Based on the FSD and FAM holdings as of September 21, 2023,
the Combined Fund expects to sell approximately 99% of FAM’s portfolio following the closing of the Reorganization. The Combined
Fund currently does not expect to sell any of FSD’s portfolio following the closing of the Reorganization. As of September 21,
2023, the expected cost to sell 99% of FAM’s holdings following the closing of the Reorganization, which is estimated to equal 7.7%
of the Combined Fund's portfolio, would be approximately $315,300 (or 0.04% of the estimated NAV of the Combined Fund as of September 21,
2023) or $0.0026 per share and would be borne by the Combined Fund.

To the extent there are any
transaction costs (including brokerage commissions, transaction charges and related fees) associated with the sales and purchases
made in connection with the Reorganizations, these will be borne by the Acquired Fund with respect to the portfolio transitioning
conducted before the Reorganizations and borne by the Combined Fund with respect to the portfolio transitioning conducted after the
Reorganizations. To the extent an Acquired Fund has holdings in France, Spain and/or Italy, such countries may impose an additional
foreign transfer tax on the transfer of such securities to the Acquiring Fund. These taxes are in addition to the transaction costs
disclosed above and would be borne by the Combined Fund.

The Registrant respectfully notes that it discloses
the tax impact of repositioning in the Synopsis in the fourth paragraph on page 7, which states: “The portfolio transitioning
after the Reorganization discussed above may result in capital gains or losses, which may have federal income tax consequences. For example,
if the Reorganization of FAM only was completed on September 21, 2023, it is estimated that approximately $10,756,000, or $0.088
per share, in capital losses would have resulted from portfolio transitioning in the Combined Fund following the Reorganization.”
The Registrant has revised the disclosure in response to this comment by adding the following at the end of the fourth paragraph on Page 7:
 “Please see the Question ‘Are the Reorganizations expected to be taxable to the respective shareholders of each Acquired Fund?’
and ‘Board Consideration of the Reorganizations’ and ‘Material Federal Income Tax Consequences of the Reorganizations’
for additional information”.

Comment
9: With respect to the following question and answer in the Questions and Answers section of the Proxy Statement/Prospectus:
 “Who will pay for the costs associated with each Reorganization?”, please disclose who will pay the estimated costs for each
Reorganization following the sentence of the answer: “The expenses of the Reorganizations are estimated to be approximately $589,000
for FSD and approximately $453,000 for FAM.”

Response:
The Registrant respectfully notes that immediate