SecProbe.io

December  15, 201 4

Via E -mail
Mr. Patrick Goulding
Chief Financial Officer
American Realty Capital Global Trust, Inc.
405 Park Avenue , 14th Floor
New York , NY  10022

Re: American Realty Capital Global Trust, Inc.
 Form 10-K for the  fiscal  year ended December  31, 2013
Filed March  7, 201 4
File No. 0-55202

Dear Mr. Goulding :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response .  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for the fiscal year ended December 31, 201 3

Item 1. Business, page 5

1. We note that you invest in net leases and that you consider tenant creditworthiness in
your evaluation of inves tment opportunities.   In future filings, please also include a
discussion of how management monitors the tenant credit quality of its current
portfolio.

Mr. Patrick Goulding
 American Realty Capital Global Trust, Inc.
 December  15, 201 4
 Page 2

 Notes to Consolidated Financial Statements

Note 2 – Summary of Significant Accounting Policies

Real Estate Investments, page F -9

2. Please tell us and disclose your policy for determining whether the acquisition of real
estate is a business or asset purchase and the result of that determination on how your
record the cost of the transact ion.  Please ensure you address sale/leaseback transactions
in your disclosure.

Form 8 -K’s filed on May 7, 2013, June 10, 2013 and July 24, 2013

3. We note that you have presented within each of the above -referenced Form 8 -K’s
summary financial information  for Travis Perkins plc, Everything Everywhere Limited
and Thames Water Utilities Limited, along with disclosure as to where audited financial
statements could be located on the internet for these companies.  Please tell us how you
have complied with the a pplicable rules to provide financial statements of significant
asset concentrations as these financial statements have not been filed pursuant to the
Exchange Act.

We urge all who are responsible for the accuracy and adequacy of the disclosure in the
filing to be certain that the filing includes the information the Securities Exchange Act of 1934
and all applicable Exchange Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they ar e responsible for the accuracy
and adequacy of the disclosures they have made.

            In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proce eding initiated by
the Commission or any person under the federal securities laws of the United States.

Mr. Patrick Goulding
 American Realty Capital Global Trust, Inc.
 December  15, 201 4
 Page 3

 You may contact Howard Efron, Staff Accountant, at (202) 551 -3439 or me at (202) 551 -3629 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Sara von Althann , Staff Attorney, at (202) 551 -3207 or Erin Martin , Staff A ttorney , at
(202) 551 -3391 with regard to legal comments.

Sincerely,

        /s/ Kevin Woody

Kevin Woody
Branch Chief