SecProbe.io

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 October 10, 2025

 VIA EDGAR

 Mr. David Orlic

 Ms. Christina DiAngelo Fettig

 Division of Investment Management

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 abrdn Global Dynamic Dividend Fund

 Registration Statement filed on Form N-2

 File Nos. 333-289796 and 811-21901

 Mr. Orlic and Ms. DiAngelo Fettig:

 On behalf of abrdn Global Dynamic Dividend Fund
(the "Fund"), we are writing to respond to the comments of the staff (the "Staff") of the Securities and Exchange
Commission (the "SEC") provided by Ms. DiAngelo Fettig in a telephone conversation with me and Kimberley Church of Dechert
LLP on September 22, 2025, and provided by Mr. Orlic in a telephone conversation with me and Ms. Church on September 24,
2025, relating to the Fund's registration statement on Form N-2 (the "Registration Statement") filed on August 22,
2025.

 For your convenience, the substance of those comments
has been restated below. The Fund's response to each comment is set out immediately under the comment. Capitalized terms used in
this letter and not otherwise defined herein shall have the meanings specified in the Registration Statement.

 Accounting Comments

 Comment 1 : For future filings, please
include in the transmittal letter the reason for the filing.

 Response : The Fund will include
the reason for the filing in future transmittal letters.

 Comment 2 : Given that the Registration
Statement is being filed pursuant to General Instruction A.2 of Form N-2, please supplementally confirm that the Fund's future
N-CSR filings will include an auditor's consent and will include the disclosures required by Instruction 4.h. to Item 24 of Form N-2.

 Response : The Fund so confirms.

 Comment 3 : Footnote 5 to the fee
table indicates that the "Interest expenses on bank borrowings" line item is based on average total borrowings of $4,899,941.
However, the amount drawn on the Fund's line of credit had increased to $18,356,064 as of the most recent semi-annual period. Please
supplementally explain whether an estimate based on $4,899,941 is reasonable considering the recent increase in the line of credit outstanding.

 Response : The amount of borrowing
by the Fund fluctuates up and down throughout the year. For example, during the semi-annual period ended April 30, 2025, the amount
drawn on the line of credit fluctuated between $0 and $20,762,876 with an average amount outstanding of $4,899,941, and more recently,
during the fiscal year-to-date period from November 1, 2024 through September 30, 2025 has fluctuated between $0 to $20,762,876
with an average amount outstanding of $5,994,831. In addition, while the amount drawn on the Fund's line of credit had increased
to $18,356,064 as of the end of most recent semi-annual period, the Fund does not anticipate its estimated average borrowings to approach
that amount for the upcoming fiscal year. Although the Fund's estimated average total borrowings may be subject to change based
on market conditions, we believe that basing the estimated "Interest expenses on bank borrowings" line item on average total
borrowings of $4,899,941 during the semi-annual period ended April 30, 2025 is reasonable and more line with the Fund's anticipated
interest expense for the upcoming fiscal year.

 Comment 4 : The Staff notes that
the expense example does not include sales load or estimated offering costs. Accordingly, please supplementally confirm that the prospectus
supplement will include the effect of any applicable sales loads and offering costs.

 Response : The Fund so confirms.

 Comment 5 : Please explain how the
disclosure requirements of Item 4.3 of Form N-2, with respect to the audit requirement for senior securities, have been met.

 Response : The Fund confirms that
it has incorporated the audited senior securities information by reference to its audited financial highlights consistent with the "Dear
Chief Financial Officer" letter from the Chief Accountant of the Division of Investment Management Annual Industry Comment Letter
dated February 14, 2001 (the " Dear CFO Letter"). To meet the audit requirement of Item 4.3 of Form N-2, the Dear
CFO Letter states that the independent accountant must express an opinion on the senior securities table itself or financial highlights
that include the senior securities table, and registrants must include, or incorporate by reference, this opinion in the registration
statement. The Dear CFO Letter notes that one way to meet the audit requirement of Item 4.3 of Form N-2 is for registrants to include
the senior securities table information with the per share and ratio information in the financial highlights. Since the financial highlights
are specifically covered by the audit opinion, the senior securities table information also would be covered. In line with the Dear CFO
Letter, the Fund has incorporated the audited senior securities information by reference to its audited financial statements on Form N-CSR,
which includes the financial highlights containing the audited senior securities information and the opinion of its independent registered
public accounting firm thereon. Accordingly, the Fund believes that it has satisfied the requirement to include audited senior securities
information in the Registration Statement.

 Comment 6 : Footnote 2 to the senior
securities table indicates that the Fund is disclosing an asset coverage ratio that is calculated by dividing net assets plus the amount
of any borrowings for investment purposes by the amount of the line of credit. Please supplementally confirm that the asset coverage calculations
were performed in accordance with Section 18 of the Investment Company Act of 1940. In addition, if the Fund is using an asset coverage
ratio rather than asset coverage per unit, please revise the column heading titled "Asset Coverage Per Unit" accordingly.

 Response : The Fund confirms that
the asset coverage ratio was calculated by dividing total assets (less all liabilities and indebtedness not represented by senior securities)
by the aggregate amount of senior securities representing indebtedness, in accordance with Section 18 of the Investment Company Act
of 1940.

 The Fund has revised the disclosure in footnote
2 as follows (added text bold and underlined; deleted text struck through):

 Asset coverage ratio is calculated by
dividing net assets plus the amount of any borrowings for investment purposes total assets (less all liabilities and
indebtedness not represented by senior securities) by the amount of the line of credit.

 The Fund has also revised the column heading titled
 "Asset Coverage Per Unit" accordingly.

 Comment 7 : Footnote 3 to the senior
securities table indicates that the column titled "Asset Coverage Per $1000" represents the "average managed asset coverage"
per every $1,000 of the total loan amount outstanding. The Staff notes that asset coverage should be disclosed as of a specific point
in time rather than as an average, and that the term "managed asset" is not defined or used elsewhere. Please revise or define
this term.

 Response : The Fund has revised the
footnote as follows (deleted text struck through):

 Represents the average managed
asset coverage per every $1,000 of the total loan amount outstanding.

 Disclosure Comments

 Comment 8 : Please remove disclosure
referring to the SEC's public reference facilities, which have all closed.

 Response : The Fund has revised the
disclosure accordingly.

 2

 Comment 9 : The Staff notes that
the Fund has entered into a line of credit with BNP Paribas Prime Brokerage International Ltd. ("BNPP PB") that was not filed
with the Registration Statement. Please file the agreement or explain why the agreement is not required to be filed pursuant to Item 25(2)(k) to
Form N-2.

 Response : The Fund has
a US PB Agreement with BNPP PB which provides a secured, uncommitted line of credit for the Fund where selected Fund assets are pledged
against advances made to the Fund, as described in the Registration Statement. The agreement was entered into when the Fund was named
 "Alpine Global Dynamic Dividend Fund." A copy of this agreement was referenced in Part C, Item 2(k)(4) as
 "Facility Agreement" and filed as exhibit 2(k)(4) to the Registration Statement at https://www.sec.gov/Archives/edgar/data/1362481/000110465925081881/tm2523786d1_ex99-2xkx4.htm .

 Comment 10 : Please revise the undertaking
in Item 34(7) of Part C to comply with the requirements of Form N-2.

 Response : The Fund has revised the
disclosure as follows (added text bold and underlined):

 The Registrant undertakes to send by
first class mail or other means designed to ensure equally prompt delivery, within two business days of receipt of a written or oral request,
any prospectus or Statement of Additional Information.

 Comment 11 : With respect to the
control share acquisition statute (the "Control Share Statute") contained in Subchapter III of the Delaware Statutory Trust
Act (the "DSTA"), please disclose: (i) the rationale for not broadly exempting application of the Control Share Statute;
and (ii) whether the Board has considered the provisions and determined that they are in the best interest of the Fund and its shareholders.

 Response : The Fund has revised the
disclosure as follows (deleted text struck through and added text bolded and underlined):

 Once a shareholder reaches a threshold,
such shareholder has no voting rights under the DSTA with respect to shares acquired in excess of that threshold (i.e., the "control
shares") unless approved by a vote of the non-acquiring shareholders, or otherwise exempted by the fund's board of trustees.
Approval by non-acquiring shareholders requires the affirmative vote of two-thirds of all votes entitled to be cast on the matter, excluding
shares held by the acquiring shareholder and its associates as well as shares held by certain insiders of a Fund. Alternatively, the Board
is permitted, but not obligated, to exempt acquisitions specifically, generally, or generally by type of control shares, either in advance
or retroactively. As of the date hereof, the Board has not received notice of the occurrence of a control share acquisition or been
requested to exempt any acquisition. As of the date hereof, Accordingly, the Board has not had
occasion to consider or determine whether the application of the Control Share Statute to a specific acquisition of Fund shares is in
the best interest of the Fund and its shareholders or should be exempted any acquisition of control shares nor made any
determination with respect to the provisions of the Control Share Statute . The Board has also not had any reason to address
these issues in the abstract, as opposed to in a specific context.

 * *
* *
*

 Please contact the undersigned at 202-261-3386
should you have any questions regarding this matter.

 Sincerely,

 /s/ William J. Bielefeld

 William J. Bielefeld

 3

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April 30, 2024

VIA EDGAR

Brian Szilagyi

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:

    abrdn Income Credit Strategies Fund (Investment Company Act File No. 811-22485); abrdn Global Dynamic Dividend Fund (Investment Company Act File No. 811-21901); abrdn Total Dynamic Dividend Fund (Investment Company Act File No. 811-21980); and abrdn Global Premier Properties Fund (Investment Company Act File No. 811-22016) (each a “Registrant” or “Fund”, and collectively, the “Registrants” or “Funds”)

Dear Mr. Szilagyi:

On March 15, 2024, you provided comments on the Registrants’
Annual Reports to shareholders on Form N-CSR (each an “Annual Report” and, collectively, the “Annual Reports”)
for the fiscal year ended October 31, 2023 filed on January 8, 2024. For your convenience, the substance of your comments has been restated
below to the best of the Registrants’ understanding. Responses from the Registrants are set out immediately under the restated comment.
Defined terms, unless otherwise defined herein, have the meanings given them in the Annual Reports.

Comment No. 1: With respect to the abrdn Income Credit Strategies
Fund, please explain why, in the senior securities table, the Registrant did not express asset coverage for each class of senior securities
in terms of dollar amounts per share (in the case of preferred stock). See Instruction 2 to Item 4.3 of Form N-2. Please also explain
why, in the senior securities table, the average market value per unit, including the method used to determine the averages (e.g. weighted,
monthly, daily, etc.) was not disclosed. See Instruction 4 to Item 4.3 of Form N-2.

Response: The Registrant confirms that for future reports, it
will update the method by which it shows asset coverage to comply with Instruction 2 to Item 4.3 of Form N-2 as it relates to preferred
shares, and will express asset coverage for each class of senior securities in terms of dollar amounts per share (in the case of preferred
stock). In addition, the Registrant confirms that for future reports, it will disclose the method used to determine the average market
value per unit (e.g., weighted, monthly, daily, etc.), consistent with Instruction 4 to Item 4.3 of Form N-2. With respect to the method
used, the Registrant further confirms that the asset coverage ratio for the Fund’s total leverage is calculated by dividing net
assets as of each fiscal period end plus the amount of any borrowings for investment purposes outstanding as of each fiscal
period end by the amount of any borrowings outstanding as of each fiscal period end, and then multiplying by $1,000.

Comment 2: With respect to the abrdn Income Credit Strategies
Fund, please explain why the disclosures that require an entity to include unobservable inputs, and the impact to valuation if there is
an increase or decrease in those inputs, are not shown in the financial statements. See ASC 820-10-50-2G and 7.228 of the AICPA audit
and accounting guide for an example.

Response: The Registrant confirms that it will include the disclosures
referenced by the Staff in future reports.

Comment No. 3: With respect to the abrdn Global Premier Properties
Fund, the Staff noted that the Fund held REITs. Please consider adding disclosure to the Notes to Financial Statements to state how the
Fund estimates the return of capital amounts resulting from distributions from underlying REITs.

Response: The Registrant confirms that it will include the disclosures
referenced by the Staff in future reports.

1900 Market Street, Suite 200 Philadelphia,
PA 19103 T +(1) 215 405 5700 F +(1) 215 405 2384

    abrdn plc is registered in Scotland
    (SC286832) at 1 George Street, Edinburgh, EH2 2LL.

    www.abrdn.com

    © abrdn plc 2021. All rights
    reserved.

Comment No. 4: With respect to each Registrant, it appears
that the Form N-CSR for the period ended October 31, 2023 refers to a fiscal quarter of the period covered by the report for the disclosure
related to Form N-CSR Item 11(b). Please utilize the language provided in Form N-CSR Item 11(b) which refers to the period covered by
the report, not isolated to a particular quarter and confirm that there have been no changes in the Registrants’ internal control
over financial reporting that occurred during the period.

Response: Each Registrant confirms that for future reports,
it will use the language provided in Form N-CSR Item 11(b) referring to the period covered by the report and not a particular quarter.
In addition, each Registrant confirms that there have been no changes in such Registrant’s internal control over financial reporting
that occurred during the period covered by its respective Annual Report.

Comment No. 5; With respect to the Annual Report for the
abrdn Global Dynamic Dividend Fund and abrdn Total Dynamic Dividend Fund, given the amount of reclaims receivable, please explain which
country or countries these receivables relate to, and how the Funds monitor the collectability of those receivables.

Response: The majority of the reclaims receivable relate to
the following countries: Switzerland, Germany, France, and Denmark. The Funds’ custodian monitors the Funds’ eligibility to
file for tax reclaims and files applications for the tax reclaims on behalf of the Funds based on information received in part from the
Funds’ adviser and remains in contact with local authorities. The adviser regularly monitors the custodian’s activity (on
a monthly basis) to ensure that paperwork is filed within deadlines and monitors for payment (on a monthly or quarterly basis). During
the time during which the adviser anticipates that the Funds are due payment, the adviser regularly monitors for the receipt of such payments
and follows up with the Funds’ custodian to determine why payments remain outstanding, if applicable, and for status updates on
the latest correspondence with local authorities relating to the reclaims.

Comment No. 6: With respect to the abrdn Income Credit Strategies
Fund, please confirm that other income, including income for payment-in-kind (PIK) interest, which exceeds 5% of the total income has
been stated separately.

Response: The Registrant confirms that other income, including
income for PIK interest, was not greater than 5% for the fiscal year ended October 31, 2023.

Comment No. 7: With respect to the abrdn Income Credit Strategies
Fund, for each security that the Fund holds that pays a combination of cash and PIK interest, please disclose both the cash and PIK rates
in the security description, or in a footnote to the schedule of investments. See AICPA audit risk alert Investment Companies 2013/2014.

Response: The Registrant confirms that, for future reports,
it will disclose both the cash and PIK rates in the security description, or in a footnote to the schedule of investments, for each security
that the Fund holds that pays a combination of cash and PIK interest.

Comment No. 8: With respect to the abrdn Income Credit Strategies
Fund, the report of independent registered public accounting firm does not indicate whether the last five fiscal years’ information
contained in the senior securities table has been audited. Please re-file the financial statements with an updated report of independent
registered public accounting firm, identifying the results of the audit of the senior securities table. Alternatively, as the Fund has
filed a registration statement on Form N-2 pursuant to General Instruction A.2, please amend such registration statement to include the
required senior securities information and include, as an exhibit, a report of independent registered public accounting firm, identifying
the results of the audit of the senior securities table. See Instruction 1 to Item 4.3 of Form N-2.

Response: The Registrant intends to file an amendment to its
registration statement on Form N-2 to include the required senior securities information and will include, as an exhibit, a report of
independent registered public accounting firm, identifying the results of the audit of the senior securities table.

1900 Market Street, Suite 200 Philadelphia,
PA 19103 T +(1) 215 405 5700 F +(1) 215 405 2384

    abrdn plc is registered in Scotland
    (SC286832) at 1 George Street, Edinburgh, EH2 2LL.

    www.abrdn.com

    © abrdn plc 2021. All rights
    reserved.

* * *

Should you have any questions concerning the above,
please call the undersigned at (267) 614-6061.

    Very truly yours,

    /s/ Katherine Corey

    Katherine Corey

    cc:

    Sharon Ferrari, Treasurer of the Fund

    Lucia Sitar, Vice President of the Fund

    Tom Bogle, Dechert LLP

    Michael Malloy, Faegre Drinker Biddle & Reath LLP

1900 Market Street, Suite 200 Philadelphia,
PA 19103 T +(1) 215 405 5700 F +(1) 215 405 2384

    abrdn plc is registered in Scotland
    (SC286832) at 1 George Street, Edinburgh, EH2 2LL.

    www.abrdn.com

    © abrdn plc 2021. All rights
    reserved.

CORRESP
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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

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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 Statements/Prospectuses”) 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 telephone conversation with Ashley Vroman-Lee and Brooke Clark of Dechert LLP on September 27, 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 applicable to each Proxy Statement/Prospectus

Comment 1:                 With respect to previous Comment 3 provided on September 2, 2022, please confirm any material considerations adverse to the Reorganization proposal are disclosed and fairly described. Please see Items 3(b) and 4(a) of Form N-14 and Item 22(c)(11) of Schedule 14A.

Response:                     Additional disclosure has been added in response to the Staff’s comment.

Comment 2:                 With respect to previous Comment 4 provided on September 2, 2022, and with respect to the disclosure discussing the possibility of converting to an open-end fund, please revise the disclosure to reflect that the Acquiring Funds have no plans to convert to an open-end fund structure or please consider removing the disclosure.

1

Response:                     The disclosure has been removed.

*                    *                     *                     *                    *

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

2

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September 14, 2022

VIA EDGAR

Ms. Ashley Vroman-Lee

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Re:      Response to Comments
on the Preliminary Schedule 14A filings filed on August 19, 2022 (each a “Proxy Statement” and, collectively, the “Proxy
Statements”) for abrdn Income Credit Strategies Fund (“ACP”) (SEC File No. 811-22485),
abrdn Global Dynamic Dividend Fund (“AGD”) (SEC File No. 811-21901) and abrdn Global Infrastructure Income Fund (“ASGI”)
(SEC File No. 811-23490) (each a “Fund” and, collectively, the “Funds”)

Ms. Vroman-Lee:

This letter responds to comments provided by telephone
on August 25, 2022, with respect to the Proxy Statements. On behalf of the Funds, your comments and our responses thereto are provided
below. All defined terms in this letter have the same meaning as the Proxy Statements, except as defined herein.

Comment applicable to abrdn Global Infrastructure
Income Fund only

Comment 1: Please move the following
disclosure from the response to the question “Why is a shareholder meeting being held?”

Additionally, to promote continuity
in the oversight of the Combined Fund, at the next regularly scheduled meeting of the Fund’s Nominating and Corporate Governance
Committee (the “Committee”), the Committee will consider recommending the nomination of Gordon A. Baird, Thomas W. Hunersen
and Chris LaVictorie Mahai, each currently a member of the Board of Directors of the Acquired Fund (the “Acquired Fund Board”),
to the Board of Trustees of the Fund, subject to approval by shareholders at the next annual general meeting of the shareholders of the
Fund.

Response: The disclosure has been
moved to the response to the question “How will the Reorganization affect the Fund and its shareholders?”.

Comments applicable to each Proxy Statement

Comment 1: In response to the question
 “Why is the Reorganization being proposed?”, please delete the following.

None of the Directors, including those
who are not “interested persons” of the Acquired Fund (the “Independent Directors”) as that term is defined in
the Investment Company Act of 1940, as amended (the “1940 Act”), have any interest in the Reorganization, and the Acquired
Fund Board, including all of the Independent Directors voting separately, unanimously approved the Reorganization.

Response: The disclosure has been
deleted.

Comment 2: In response to the question
 “How will the Reorganization affect the Fund and its shareholders?”, please make clear that there is no guarantee that any
benefit will occur as a result of the Reorganization and disclose any potential negative consequences of the Reorganization.

Response: The disclosure has been
amended as follows (new text underlined):

There can be no guarantee that any anticipated
benefits will occur as a result of the Reorganization. Additionally, among other potential consequences of the Reorganization, portfolio
transitioning due to the Reorganization may result in capital gains or losses, which may have federal income tax consequences for shareholders
of the Combined Fund. Please see “Board Considerations” in the Proxy Statement for additional information.

    1

Comment 3: In response to the question
 “How will the Reorganization affect the Fund and its shareholders?”, please disclose the possibility of a tax impact to the
Fund and its shareholders.

Response: Please see the response
to Comment 2 above.

Comment 4: In response to the question
 “Will the Reorganization impact Fund distributions to shareholders?”, please disclose that the Combined Fund “expects
to pay” a periodic distribution rather than “would pay” a periodic distribution.

Response: The disclosure has been
revised accordingly.

Comment 5: In response to the question
 “Will there be any significant portfolio transitioning in connection with the Reorganization that impacts Fund shareholders?”,
please include the costs of portfolio transitioning and who will pay these costs.

Response: The following disclosure
has been added:

ACP:

Transaction costs (including brokerage
commissions, transaction charges and related fees) associated with such sales and purchases made by the Combined Fund after the closing
of the Reorganization will be borne by the shareholders of the Combined Fund. If the Reorganization was completed on July 18, 2022, the
transaction costs anticipated to be incurred in portfolio transitioning are estimated to be approximately $968,000 (or 26 bps of the Combined
Fund’s estimated assets as of July 18, 2022). The foregoing estimates are subject to change depending on the composition of the
portfolio holdings transferred to the Acquiring Fund at closing and market circumstances when the portfolio transitioning occurs.

AGD:

Transaction costs (including brokerage
commissions, transaction charges and related fees) associated with such sales and purchases made by the Combined Fund after the closing
of the Reorganization will be borne by the shareholders of the Combined Fund. If the Reorganization of DEX only was completed on July
18, 2022, the transaction costs anticipated to be incurred in portfolio transitioning are estimated to be approximately $294,000 (or 10
bps of the Combined Fund’s estimated NAV as of July 18, 2022). This breaks down across commissions costs of roughly $30,000, and
spread related costs for fixed income and international securities of approximately $209,000 and stamp duties/taxes of $54,000. If the
Reorganization of DDF only was completed on July 18, 2022, the transaction costs anticipated to be incurred in portfolio transitioning
are estimated to be approximately $132,000 (or 5 bps of the Combined Fund’s estimated NAV as of July 18, 2022). This breaks down
across commissions costs of roughly $21,000, and spread related costs for fixed income and international securities of approximately $84,000
and stamp duties/taxes of $27,000. If both Reorganizations were completed on July 18, 2022, the transaction costs anticipated to be incurred
in portfolio transitioning are estimated to be approximately $426,000. The foregoing estimates are subject to change depending on the
composition of the portfolio holdings transferred to the Acquiring Fund at closing and market circumstances when the portfolio transitioning
occurs.

ASGI:

Transaction costs (including brokerage
commissions, transaction charges and related fees) associated with such sales and purchases made by the Combined Fund after the closing
of the Reorganization will be borne by the shareholders of the Combined Fund. If the Reorganization was completed on July 18, 2022, the
transaction costs anticipated to be incurred in portfolio transitioning are estimated to be approximately $397,000 (or 8 bps of the Combined
Fund’s estimated NAV as of July 18, 2022). This breaks down across commission costs of roughly $83,000, spread related costs for
international securities of approximately $138,000 and stamp duties/taxes of $176,000. The foregoing estimates are subject to change depending
on the composition of the portfolio holdings transferred to the Acquiring Fund at closing and market circumstances when the portfolio
transitioning occurs.

    2

Comment 6: In response to the question
 “Is the Reorganization expected to be taxable to shareholders of the Fund?”, please consider disclosing whether portfolio
transitioning is likely to result is a capital gain or a capital loss and whether such gain or loss is expected to be significant.

Response: The following disclosure
has been added:

ACP:

For example,
if the Reorganization was completed on March 31, 2022, it is estimated that approximately
$13.37 million, or $0.27 per share, in capital losses would have resulted from portfolio
transitioning in the Fund following the Reorganization.

The actual tax consequences as a result
of portfolio repositioning after the closing of the Reorganization is dependent on the portfolio composition of the Acquired Fund at the
time of closing and market conditions. Any net capital gain resulting from the realignment coupled with the results of the Fund’s
normal operations during the tax year following the close of the Reorganization would be distributed to the shareholder base of the Combined
Fund post-Reorganization in connection with the annual distribution requirements under U.S. federal tax laws.

AGD:

For example, if the Reorganization of
DEX only was completed on May 31, 2022, it is estimated that approximately $5.86 million, or $0.27 per share, in capital losses would
have resulted from portfolio transitioning in the Fund following the Reorganization. If the Reorganization of DDF only was completed on
May 31, 2022, it is estimated that approximately $6.99 million, or $0.37 per share, in capital gains would have resulted from portfolio
transitioning in the Fund following the Reorganization. If both Reorganizations were completed on May 31, 2022, it is estimated that approximately
$113 million, or $0.04 per share, in capital gains would have resulted from portfolio transitioning in the Fund following the Reorganizations.
As of October 31, 2021, AGD has a capital loss carryfoward of $14,214,753 which could be used to offset the gains estimated to be generated
from the sales of securities post-merger from DDF.

The actual tax consequences as a result
of portfolio repositioning after the closing of a Reorganization is dependent on the portfolio composition of the relevant Acquired Fund
at the time of closing and market conditions. Any net capital gain resulting from the realignment coupled with the results of the Fund’s
normal operations during the tax year following the close of the Reorganization would be distributed to the shareholder base of the Combined
Fund post-Reorganization in connection with the annual distribution requirements under U.S. federal tax laws.

ASGI:

For example,
if the Reorganization was completed on May 31, 2022, it is estimated that approximately
$21.64 million, or $0.85 per share, in capital gains would have resulted from portfolio transitioning in the Fund following the Reorganization.

The actual tax consequences as a result
of portfolio repositioning after the closing of the Reorganization is dependent on the portfolio composition of the Acquired Fund at the
time of closing and market conditions. Any net capital gain resulting from the realignment coupled with the results of the Fund’s
normal operations during the tax year following the close of the Reorganization would be distributed to the shareholder base of the Combined
Fund post-Reorganization in connection with the annual distribution requirements under U.S. federal tax laws. In addition, the Fund is
covered by an exemptive order received by the Fund’s investment adviser from the U.S. Securities and Exchange Commission. The exemptive
relief allows the Fund to distribute long-term capital gains as frequently as monthly in any one taxable year. It is possible that gains
generated post-Reorganization may be used to supplement the monthly distribution payable to the Combined Fund’s shareholders.

Comment 7: Under “Proposal,”
please include disclosure regarding capital gains or losses, which may have federal income tax consequences for shareholders of the Combined
Fund.

Response: The disclosure has been
amended to include the information provided in response to Comment 6 above.

    3

Comments applicable to abrdn Income Credit
Strategies Fund only

Comment 1: Given that the Fund is
currently trading at a premium whereas the Acquired Fund is currently trading at a discount and that the Reorganization is taking place
at net asset value, please disclose that the market value of the Combined Fund could be adversely affected by shareholders of the Acquired
Fund selling out of the Combined Fund after the Reorganization.

Response: The following disclosure
has been added:

To the extent the Acquired Fund is trading
at a discount to its net asset value and the Fund is trading at a premium to its net asset value at the time of the Reorganization, Acquired
Fund shareholders would have the potential for an economic benefit. There can be no assurance that, after the Reorganization, common shares
of the Combined Fund will trade at, above or below net asset value. The market value of the common shares
of the Combined Fund may be less than the market value of the common shares of the Fund prior to the Reorganization.

Comment 2: Please align the expenses
of the Fund presented in the “Fees and Expenses Table” with those presented in the Financial Highlights for the six-month
period ended April 30, 2022, in the Fund’s Semi-Annual Report for the fiscal period ended April 30, 2022.

Response: There are certain differences
between the requirements for inclusion of items in the Fund’s Fees and Expenses Table and financial reporting requirements relating
to the Financial Highlights in the Fund’s Semi-Annual Report. For purposes of the Fees and Expenses Table, “dividends on preferred
shares” are required to be reflected as an expense line item; however, according to U.S. GAAP, such amounts are considered distributions
to shareholders and are therefore reflected as such under operating performance, and not as a fund expense, in the Fund’s Semi-Annual
Report. In addition, the Fund has acquired fund fees and expenses, which are required to be reflected as an expense item in the Fees and
Expenses Table, but which are not required to be included as part of the Fund’s expense ratio in its Semi-Annual Report. The Registrant
believes that these two items account for the discrepancies between the Fees and Expenses Table and the Financial Highlights presented
in the Fund’s Semi-Annual Report; as a result, the Registrant has not made any changes to the Fees and Expenses Table in response
to this comment.

Please contact the undersigned at 202-261-3360
should you have any questions regarding this matter.

    Sincerely,

    /s/
    Thomas C. Bogle

    Thomas C. Bogle

    4

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    787 Seventh Avenue

New York, NY 10019-6099

Tel: 212 728 8000

Fax: 212 728 8111

January 4, 2018

Deborah O’Neal-Johnson

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: Alpine Total Dynamic Dividend Fund (File No. 811-21980)

Alpine Global Dynamic Dividend Fund
(File No. 811-21901)

Alpine Global Premier Properties
Fund (File No. 811-22016)

Dear Ms. O’Neal-Johnson:

On behalf of Alpine Total Dynamic Dividend
Fund (“AOD”), Alpine Global Dynamic Dividend Fund (“AGD”) and Alpine Global Premier Properties Fund (“AWP”)
(each a “Fund,” and collectively, the “Funds”), this letter responds to comments provided by the staff
of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
to Neesa P. Sood by telephone on December 29, 2017 and discussed with Ryan P. Brizek by telephone on January 3, 2018 regarding
the preliminary proxy statements filed with respect to each Fund (each, a “Proxy Statement” and collectively, the “Proxy
Statements”).

For your convenience, the substance
of those comments has been restated below. The Funds’ response to each comment is set out immediately under the restated
comment. Please note that we have not independently verified information provided by the Funds. Capitalized terms have the meanings
assigned in the Proxy Statement unless otherwise defined in this letter.

Comment No. 1:          Please
more precisely describe the terms of the advisory fee for the Funds that can charge an advisory fee on managed assets.

Response:                   AOD
and AWP can currently charge an advisory fee on leveraged assets. Under the New Advisory Agreement for each of these Funds
there will be no change in how advisory fees are calculated on borrowings, but the managed assets on which the investment
adviser may charge an advisory fee will be specified for AOD and expanded for AWP to allow the investment adviser to charge
an advisory fee on liabilities attributable to all forms of leverage, including the issuance of debt securities.

In light of the Staff’s comment,
each of AOD and AWP will disclose that the managed assets on which Aberdeen may charge an advisory fee will include assets
plus liabilities attributable to all forms of leverage, including the issuance of debt securities, in order to specify (for
AOD) or broaden (for AWP) the categories of leverage on which an advisory fee may be charged. The
Q&A disclosure for these Funds will also be updated to include the definition of “Managed Assets” that is
disclosed in the chart in the “Comparison of the Alpine Advisory Agreement and New Advisory Agreement” section of
the Proxy Statement and the form of New Advisory Agreement in Exhibit A.

New
York   Washington   Houston   Paris   London   Frankfurt   Brussels   Milan   Rome

in alliance
with Dickson Minto W.S., London and Edinburgh

Comment No. 2:          Please
confirm to the Staff that each New Advisory Agreement will not result in an increase in the aggregate advisory fees borne by the
Funds.

Response:	                Under
the current Alpine Advisory Agreements, AGD may charge a 1.00% advisory fee on net assets, AOD may charge a 1.00% advisory fee
on total assets (i.e., on leveraged assets) and AWP may charge a 1.00% advisory fee on  managed assets (i.e.,
on leveraged assets). If AOD or AWP draws down on its bank line of credit today then it will incur additional aggregate
advisory fees because the Alpine Advisory Agreement for each of these Funds permits Alpine to charge an advisory fee on the
principal amount of any borrowings for investment purposes. Similarly, the New Advisory Agreement for each of AOD and AWP
would allow Aberdeen to charge an advisory fee on the principal amount of any borrowings for investment purposes. Thus, each
Fund has confirmed that its New Advisory Agreement will not result in a Fund bearing increased aggregate advisory fees
immediately following the Transaction. However, since the leveraged assets on which an advisory fee could be charged will be
expanded under the New Advisory Agreement for AWP to allow AWP to charge an advisory fee on liabilities attributable to the
issuance of debt securities, if AWP were to issue debt securities in the future then Aberdeen could charge an advisory fee on
the liabilities attributable to those debt securities. As a result, AWP has added the following disclosure:

Under both the Alpine Advisory
Agreement and the New Advisory Agreement, the investment adviser may charge an advisory fee on the principal amount of any borrowings
for investment purposes. The New Advisory Agreement, however, will expand the types of managed assets on which the investment adviser
may charge an advisory fee to allow the investment adviser to charge an advisory fee on liabilities attributable to all forms of
leverage, including the issuance of debt securities. These costs related to the use
of leverage would be incurred to seek to increase the Fund’s total return, although that cannot be guaranteed.

Comment No. 3:          In
the Answer to the Question “Will the fee rates payable under the New Investment Advisory Agreement increase? Are total fund
expenses expected to materially change?” in the Q&A, please explain why no material changes to total fund expenses are
expected following the Transaction.

Response:	                     Each Fund has updated the
Answer to the Question to revise the relevant disclosure as follows:

-
2 -

“Total fund expenses are
not expected to materially change following the Transaction because key fund service providers (other than the investment
adviser) are not expected to change.”

Also see the response to Comment 2 above.

Comment No. 4:            In
the Answer to the Question “Will the Fund pay for this proxy solicitation?” in the Q&A, please include the solicitation
costs (which are already disclosed in each Proxy Statement).

Response:	                      Each Fund will update the
Answer to the Question as requested to include the following disclosure at the end of the response:

AOD – The proxy solicitation costs
are expected to be approximately $115,000.

AGD – The proxy solicitation costs
are expected to be approximately $29,000.

AWP – The proxy solicitation costs
are expected to be approximately $66,000.

*        *
       *        *

Please do not hesitate
to contact me at (212) 728-8865 or Neesa P. Sood at (202) 303-1232 if you have comments or if you require additional information
regarding the enclosed materials.

Very truly yours,

/s/ Ryan P. Brizek

Ryan P. Brizek

Enclosures

 cc: Rose F. DiMartino, Willkie Farr & Gallagher LLP

Neesa P. Sood, Willkie
Farr & Gallagher LLP

-
3 -

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1875 K Street, N.W.

Washington, DC 20006-1238

Tel: 202 303 1000

Fax: 202 303 2000

March 29, 2016

Christina DiAngelo Fettig

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Re:
Alpine Income Trust (File No. 811-21210)

Alpine Series Trust (File No. 811-10405)

Alpine Equity Trust (File No. 811-05684)

Alpine Total Dynamic Dividend Fund (File No. 811-21980)

Alpine Global Dynamic Dividend Fund (File No. 811-21901)

Alpine Global Premier Properties Fund (File No. 811-22016)

(the “Registrants”)

Dear Ms. DiAngelo Fettig:

On behalf of each series of Alpine Income Trust (Alpine Ultra Short Municipal Income Fund and Alpine High Yield Managed Duration Municipal Fund), each series of Alpine Series Trust (Alpine Dynamic Dividend Fund, Alpine Financial Services Fund, Alpine Rising Dividend Fund and Alpine Small Cap Fund), each series of Alpine Equity Trust (Alpine Emerging Markets Real Estate Fund, Alpine Global Infrastructure Fund, Alpine International Real Estate Equity Fund and Alpine Realty Income & Growth Fund), Alpine Total Dynamic Dividend Fund, Alpine Global Dynamic Dividend Fund and Alpine Global Premier Properties Fund (each a “Fund,” and collectively, the “Funds”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to Neesa P. Sood by telephone on February 3, 2016 regarding the annual reports to shareholders for the fiscal year ended October 31, 2015 with respect to the Funds (each, an “Annual Report” and collectively, the “Annual Reports”).

The Annual Report with respect to Alpine Income Trust and Alpine Series Trust is referred to herein as the “Equity & Income Funds Annual Report.” The Annual Report with respect to Alpine Equity Trust is referred to herein as the “Real Estate Funds Annual Report.” The Annual Reports for each of Alpine Total Dynamic Dividend Fund, Alpine Global Dynamic Dividend Fund and Alpine Global Premier Properties Fund (the “Closed-End Funds”) are collectively referred to herein as the “Closed-End Fund Annual Reports.”

For your convenience, the substance of the Staff’s comments has been restated below. Each Registrant’s joint or individual responses to each comment, as applicable, are set out immediately under the restated comment. Unless otherwise indicated, defined terms used herein have the meanings set forth in the respective Annual Report.

Comment No. 1:   With respect to Funds that have been liquidated or merged into another Fund as a result of a reorganization, please update the status of those Funds as “inactive” on EDGAR.

New York    Washington    Houston    Paris    London     Milan    Rome    Frankfurt    Brussels

in alliance with Dickson Minto W.S., London and Edinburgh

Response:  EDGAR has been updated to reflect the status of the following funds as inactive: Alpine Municipal Money Market Fund and Alpine Global Consumer Growth Fund. EDGAR will be updated to reflect the status of Alpine Transformations Fund, Alpine Equity Income Fund, Alpine Cyclical Advantage Property Fund as inactive upon completion of the last required filing.

Comment No. 2:   In the Equity & Income Funds Annual Report and the Real Estate Funds Annual Report, please present the Institutional Class line graphs based on the minimum investment required with respect to investment in Institutional Class shares (e.g., $1,000,000 or $250,000) instead of $10,000 per Instruction 1(d) to Item 27(b)(7)(ii)(A) of Form N-1A.

Response:  In future filings, the Institutional Class line graphs will be based on a minimum investment of $1,000,000 for each series of Alpine Series Trust and Alpine Equity Trust and $250,000 for each series of Alpine Income Trust.

Comment No. 3:  With respect to Alpine Financial Services Fund in the Equity & Income Funds Annual Report, page 19 discloses a return of -2.68% for Class A shares (without load) in the Comparative Annualized Returns as of 10/31/215 chart, while the Financial Highlights table on page 80 discloses a return of -2.75% for Class A shares. On a supplemental basis, please explain the reason for this.

Response:  The Fund confirms that the Class A shares performance provided in the Financial Highlights table is correct. The Fund acknowledges the discrepancy in the returns and in future filings will ensure consistency of the returns between the chart and the Financial Highlights table.

Comment No. 4:  Page 3 of Alpine Global Premier Properties Fund’s Annual Report states that the Fund had $0.30 per share in distributions in the MD&A section, while the Financial Highlights table states $0.60 per share in distributions. On a supplemental basis, please explain the reason for this.

Response:  The Fund confirms that the distribution stated in the Financial Highlights table is correct. The Fund acknowledges the discrepancy in the disclosure of distributions and in future filings will ensure consistency of the disclosure between the MD&A section and the Financial Highlights table.

Comment No. 5:   With respect to the Alpine Global Infrastructure Fund in the Real Estate Funds Annual Report, page 3 states that it estimates that the Fund paid a portion of the 2015 distributions through a return of capital, which is not reflected by a 19(a) notice on the Fund’s website. Please confirm whether there were distributions of returns of capital.

Response:  The Fund uses the best available information in determining whether a 19(a) notice is required. At the time the determination was made, we believe that such a notice was not needed. Subsequent to the distributions in September, due to the recharacterizations of certain holdings (e.g., real estate investment trusts and passive foreign investment companies), there were distributions of returns of capital. The Annual Report includes disclosure with respect to the Fund’s distributions, characterizing it as a return of capital, as does the Form 1099, so that the shareholders of the Fund have been informed of the distributions of returns of capital.

Comment No. 6:   With respect to Alpine Ultra Short Municipal Income Fund in the Equity & Income Funds Annual Report on page 57, please consider providing more disclosure on the terms of the rate of the variable rate securities (i.e., its base rate, whether it has an interest rate floor, its LIBOR spread) in footnote (a) to the Schedule of Portfolio Investments.

Response:  The Fund will include this information in future filings.

- 2 -

Comment No. 7:   With respect to Alpine Ultra Short Municipal Income Fund in the Equity & Income Funds Annual Report on page 56, please include the class of shares owned in each money market fund investment, if applicable, in the Schedule of Portfolio Investments.

Response:  The Funds will include the class of shares owned in each money market fund investment, if applicable, in future filings.

Comment No. 8:  Page 37 of the Real Estate Funds Annual Report shows that Alpine Emerging Markets Real Estate Fund invests 43.3% of its holdings in China. On a supplemental basis, please explain the Fund’s policy on investments in China and whether the country-specific risks are disclosed.

Response:  Alpine Emerging Markets Real Estate Fund may invest without limitation in the securities of foreign issuers that are publicly traded in the United States or on foreign exchanges. Under normal market conditions, the Fund allocates its assets among issuers located in no less than three different countries, one of which may be the United States.

The Fund has disclosure that characterizes the risk of investing in emerging market countries (which includes China) in its registration statement, including its summary prospectus. In the Fund’s annual update to its registration statement, which was filed with the SEC on February 26, 2016, additional disclosure was included, including the following: (a) that to the extent a Fund focuses its investments in a single country or only a few countries in a particular geographic region, economic, political, regulatory or other conditions affecting such country or region may have a greater impact on Fund performance relative to a more geographically diversified fund (to the summary and statutory prospectuses) and (b) risks of investing in issuers in China (in the SAI).

The Fund will supplement the prospectus to include the following disclosure “As of the date of this Prospectus, the Emerging Market Fund is subject to the risks specific to investing in China. China is an emerging market and demonstrates significantly higher volatility from time to time in comparison to developed markets. Over the last few decades, the Chinese government has undertaken reform of economic and market practices and has expanded the sphere of private ownership of property in China. However, Chinese markets generally continue to experience inefficiency, volatility and pricing anomalies resulting from governmental influence, a lack of publicly available information and/or political and social instability. Internal social unrest or confrontations with other neighboring countries, including military conflicts in response to such events, may also disrupt economic development in China and result in a greater risk of currency fluctuations, currency non-convertibility, interest rate fluctuations and higher rates of inflation. Export growth continues to be a major driver of China's rapid economic growth. Reduction in spending on Chinese products and services, institution of tariffs or other trade barriers, or a downturn in any of the economies of China's key trading partners may have an adverse impact on the Chinese economy. Investments in Hong Kong listed securities may subject the Fund to exposure to Chinese companies.” In connection with the next annual update to the registration statement, the Fund will continue to consider the inclusion of country specific risk disclosure.

Comment No. 9a:  On a supplemental basis, please explain why the following accruals are greater than the expense for the year:

Fund

Category

Expense

Accrual

Alpine Rising Dividend Fund

Trustee Fees

$646

$3,317

Alpine International Real Estate Equity Fund

Distribution Fees

$336

$1,286

Alpine Realty Income & Growth Fund

Distribution Fees

$7,044

$12,191

Alpine Emerging Markets Real Estate Fund

Distribution Fees

$1,475

$1,673

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Response:  The reason the accrual for the “Trustee Fees” for Alpine Rising Dividend Fund is higher than the expense for the year is due to the reorganization of two target funds into Alpine Rising Dividend Fund, as the accrual amount includes the two target funds. The reason the accruals are greater than the expenses for the year with respect to “Distribution Fees” for Alpine International Real Estate Equity Fund, Alpine Realty Income & Growth Fund and Alpine Emerging Markets Real Estate Fund are a result of the Funds accruing the distribution fees at the contractual 25 basis points rate while the actual payments were lower for the year.

Comment No. 9b:  Alpine Global Dynamic Dividend Fund has accruals for trustee fees in the amount of $36,203 and compliance fees of $34,159. These expenses are not disclosed separately in the Statement of Operations and the total of other expenses is $56,713, less than the accruals for trustee and compliance fees. Please explain on a supplemental basis.

Response:  The Fund notes that the discrepancy was due to over-accruals from the prior fiscal year ended October 31, 2014, which reduced the amount necessary to expense in the current fiscal year ended October 31, 2015.

Comment No. 10:    On a supplemental basis, please state whether the Closed-End Funds have received their income receivable related to a class action settlement. If not, please state how long the amounts have been outstanding.

Response:  The income from the class action settlement related to improper foreign exchange contract transactions conducted by the former custodian of the Funds has not yet been received as of the date of this letter. The Funds have been informed by counsel in the class action settlement that they are expected to receive the amounts by the end of March 2016 which have been outstanding just prior to the Funds’ fiscal year end.

Comment No. 11:   Per Item 13, Instruction 3(b) of Form N-1A, please include a note in the Financial Highlights tables that sales loads are not reflected in total returns.

Response:  In future filings, the Funds will include a note to the Financial Highlights tables with respect to Class A shares that states that “Total returns would be reduced if a sales or redemption charge was taken into account.”

Comment No. 12:   On page 90 of the Equity & Income Annual Report, the fair value chart for Alpine Dynamic Dividend Fund uses different categories to breakdown the investments from those used in the Schedule of Portfolio Investments. Please consider aligning these disclosures for the benefit of shareholders in future filings.

Response:  In future filings, the categories used in the fair value chart and in the Schedule of Portfolio Investments will be aligned.

Comment No. 13:   With respect to Alpine Rising Dividend Fund, please provide more information about the reconciliation of Level 3 assets on page 93 of the Equity & Income Funds Annual Report (i.e., quantitative information about the significant and observable inputs used in the fair value measurement).

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Response:  The Funds generally include a Level 3 roll-forward but only include a quantitative table when the value of Level 3 securities is greater than or equal to 1% of the Fund’s net assets as of the reporting date.

Comment No. 14:   Page 94 of the Equity & Income Funds Annual Report under “Federal and Other Income Taxes” notes that capital gains realized on some foreign securities are subject to foreign taxes. Please confirm whether any of the Funds paid or accrued foreign taxes on the capital gains of foreign securities. If so, please explain where the taxes were disclosed. Consider updating the note to describe the accounting policy for capital gains taxes.

Response:  The Funds have not accrued foreign taxes during the fiscal year ended October 31, 2015 because they have not had gains that were not offset by losses. The Funds will continue to evaluate when and if disclosure regarding its accounting policy for capital gains taxes is required and consider including a description of its accounting policy for capital gains taxes in future filings.

Comment No. 15:   Please state whether the Funds have rates associated with their equity-linked structured notes discussed on page 95 of the Equity & Income Funds Annual Report, and if so, please disclose those rates in the Schedule of Portfolio Investments in future filings.

Response:  The Funds have confirmed that the equity-linked notes that are held by the Funds do not have rates associated with them and, therefore, do not have related accruals. Dividends are accrued on the ex date, as they are on the underlying equity securities.

Comment No. 16:   In the Foreign Currency Translation Transactions note on page 95 of the Equity & Income Funds Annual Report, please explain whether the Funds isolate that portion of the results of operations resulting from changed in foreign exchange rates on investments from the fluctuations arising from changes in market prices of securities held.

Response:  The Funds do not isolate that portion of their net realized and unrealized gains and losses on investments resulting from changes in foreign exchange rates from the impact arising from changes in market process. Such fluctuations are included with net realized and unrealized gain or loss from investments. Net realized foreign currency transaction gains and losses arise from sales of foreign currencies, currency gains or losses realized between the trade and settlement

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Alpine Global Dynamic Dividend Fund

Alpine Total Dynamic Dividend Fund

Alpine Global Premier Properties Fund

2500 Westchester Avenue, Suite 215

Purchase, NY 10577-2540

December 30, 2013

VIA EDGAR TRANSMISSION

Ms. Kathy L. Churko

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-4720

Re:

Alpine Global Dynamic Dividend Fund (File nos. 333-152901, 811-21901)

Alpine Total Dynamic Dividend Fund (File nos. 333-152580, 811-21980) and

Alpine Global Premier Properties Fund (File nos. 333-140770, 881-22016)

(collectively the “Closed-End Trusts”)

Dear Ms. Churko:

This correspondence is being filed in response to the oral comments given to State Street Corporation via telephone conference on November 20, 2013 relating to the review of the Closed-End Trusts’ annual reports dated October 31, 2012 (the “Shareholder Reports”), each filed on Form N-CSR on January 8, 2013.

For your convenience, the Staff of the Securities and Exchange Commission’s (the “Staff’s”) comments have been reproduced in bold typeface immediately followed by the Trusts’ responses.

Alpine Global Dynamic Dividend Fund and Alpine Global Premier Properties Fund – Annual Report

1.

The Alpine Global Dynamic Dividend and Alpine Global Premier Properties appear to invest in total return swaps. Please refer to the SEC’s Concept Release No. IC 29776; Use of Derivatives by Investment Companies under the Investment Company Act of 1940.

Response:  The Closed-End Trusts acknowledge that they are aware of Concept Release No. IC 29776 and that they will monitor for future guidance from the SEC and will comply with such guidance.

All Funds – Financial Statements

2.

In the notes to financial statements of each of the Closed-End Trusts, the Derivative Instruments and Hedging Activities tables does not appear to tie to the Statement of Operations. Please explain the discrepancy.

Response:  The Derivative Instruments and Hedging Activities tables present the realized gain/loss and change in unrealized gain/loss on “forward currency contracts.”  The amounts shown in the Statement of Operations are realized and unrealized gain/loss on “foreign currency transactions.” The difference is that the Statement of Operations includes both forward and spot contracts, whereas the Derivative Instruments and Hedging Activities tables present strictly forward contracts.

All Funds – Form N-CSR

3.

For Item 4(g) of Form N-CSR, please explain the nature of the non-audit fees billed by the registrant’s accountant for services rendered to the registrant, and the registrant’s investment adviser, and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the registrant. Please explain the increase for item 4(g) of Form N-CSR from 2011 to 2012.

Response:  The increase in Item 4(g) from 2011 to 2012 is directly related to fees billed for consulting and advisory services provided to the Trusts and the Adviser regarding Enterprise Risk Management.  Please note that in Item 4(d), each Trust reported and described the amount of consulting and advisory services regarding Enterprise Risk Management allocable to each Trust.

Alpine Global Premier Properties Fund – Rule 19a-1 Notices

4.

The Schedule of Investments for the Alpine Global Premier Properties Fund appears to have a Rule 19a-1 return of capital.  Please explain how the Trust complied with Rule 19a-1.

Response:  The Alpine Global Premier Properties Fund did have a Rule 19a-1 return of capital. The Fund provided Rule 19a-1 notices to shareholders in connection with the distributions and also filed copies of such notices as exhibits to its form N-CSR.

In connection with this response to the Staff’s comments, the Closed-End Trusts, hereby state the following:

(1)

The Closed-End Trusts acknowledge that in connection with the comments made by the Staff regarding annual reports for registered investment companies filed on Form N-CSR, the Staff has not passed generally on the accuracy or adequacy of the disclosure made in the reports;

(2)

The Closed-End Trusts acknowledge that Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filings; and

(3)

The Closed-End Trusts represent that they will not assert the Staff’s review process as a defense in any action by the Commission or any securities-related litigation against the Funds.

If you have any questions regarding the enclosed, please do not hesitate to contact Matthew K. Breitman at 914-417-6385.

Very truly yours,

ALPINE GLOBAL DYNAMIC DIVIDEND FUND

ALPINE TOTAL DYNAMIC DIVIDEND FUND

ALPINE GLOBAL PREMIER PROPERTIES FUND

/s/ Ronald G. Palmer, Jr.

Ronald G. Palmer, Jr.

Chief Financial Officer

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Alpine Global Dynamic Dividend Fund

Alpine Total Dynamic Dividend Fund

Alpine Global Premier Properties Fund

2500 Westchester Avenue, Suite 215

Purchase, NY 10577-2540

March 4, 2011

VIA EDGAR TRANSMISSION

Ms. Laura Hatch

Securities and Exchange Commission

Division of Investment Management

100 “F” Street, N.E.

Washington, DC 20549

    Re:

    Alpine
    Global Dynamic Dividend Fund (File nos. 333-152901, 811-21901)

    Alpine
        Total Dynamic Dividend Fund (File nos. 333-152580, 811-21980) and

      Alpine
      Global Premier Properties Fund (File nos. 333-140770, 881-22016)(collectively
  the “Closed-End Trusts”)

Dear Ms. Hatch:

This correspondence is
being filed in response to the oral comments given to State Street Corporation via telephone conference on February 24, 2011 regarding
a Sarbanes-Oxley review of the Closed-End Trusts’ most recent annual reports, each dated October 31, 2010 and filed on Form
N-CSR with the Securities and Exchange Commission (the “SEC”) on January 7, 2011, in addition to other filings made
throughout the Closed-End Funds’ fiscal year ended October 31, 2010.

For your convenience, the
SEC Staff’s comments have been reproduced in bold typeface immediately followed by the Closed-End Trusts’ responses.

All Closed-End Trusts – 40-17G
Fidelity Bond Filings

The 40-17G Fidelity Bond filing for each Closed-End Trust disclosed
only the coverage amount attributable to the joint insureds and did not specify the coverage amount attributable to the individual
insureds. Future 40-17G Fidelity Bond filings should specify the amount of coverage attributable to each insured.

Response: The Closed-End Trusts respond
by stating that future 40-17G Fidelity Bond filings will specify the coverage amount attributable to each insured.

All Closed-End Trusts – Annual
Reports

Although Deloitte & Touche LLP was listed as the Independent
Registered Public Accounting firm elsewhere in the Annual Reports, the Reports of the Independent Registered Public Accounting
Firm were signed simply as “Milwaukee, WI, December 30, 2010” and did not include the full name and/or signature of
Deloitte & Touche LLP. Future filings and reports should include the full name and/or signature of the Independent Registered
Public Accounting firm.

Response: The Closed-End Trusts respond
by stating that future filings and reports will include the full name and/or signature of the Independent Registered Public Accounting
firm.

1

Alpine Total Dynamic Dividend Fund –
Annual Report

In its Statement of Assets and Liabilities, the Alpine Total Dynamic
Dividend Fund reported Receivables for total return swap contracts of $119,082, and Payables for total return swap contracts of
$876,243. However, the Notes to Financial Statements stated “The Fund did not hold total return swaps as of October 31, 2010.”
These statements seem inconsistent. Please explain.

Response: The Alpine Total Dynamic Dividend
Fund responds by stating that while the Fund did invest in total return swap
agreements during the year, the Fund did not hold total return swaps as of October 31, 2010. Those agreements were either settled
or terminated on or before October 31, 2010. Due to the timing of termination or settlement (which left amounts to be settled after
the transaction was terminated), $199,082 and $876,243 represented the amounts due to (owed by) the Fund at October 31, 2010.

If you have any questions regarding the Closed-End
Trusts’ responses, please do not hesitate to contact Jon-Luc Dupuy of State Street Corporation at (617) 662-1744.

Very truly yours,

/s/ Ronald G. Palmer Jr.

Ronald G. Palmer, Jr.

Chief Financial Officer

Alpine Global Dynamic Dividend
Fund

Alpine Total Dynamic Dividend
Fund

Alpine
Global Premier Properties Fund

2