Skadden, Arps, Slate, Meagher & Flom llp
DIRECT DIAL
212-735-2262
EMAIL ADDRESS
Rose.Park@SKADDEN.COM
VIA EDGAR
Ms. Laura Hatch
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
FOUR TIMES SQUARE
NEW YORK 10036-6522
(212) 735-3000
Fax: (212) 735-2000
http://www.skadden.com
June 9, 2011
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RE: |
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The Gabelli Global Gold, Natural Resources & Income Trust
(File Nos. 333-170691; 811-21698) |
Dear Ms. Hatch:
Electronically transmitted herewith for filing on behalf of The Gabelli Global Gold, Natural
Resources & Income Trust (the Fund) is the Funds Post-Effective Amendment No. 3 to its
Registration Statement on Form N-2 (the Registration Statement) under the Securities Act
of 1933, and the Investment Company Act of 1940.
The Fund has authorized us to make the following responses to the comments provided to me via
telephone on June 1, 2011. Each comment is set forth below in
bold font and the Funds response follows.
1. In the Summary of Fund Expenses section, please clarify and confirm the basis for the data
provided. The disparity between the data provided in the Financial Highlights section and the
data provided in the Summary of Fund Expenses section is a marked one, even if the latter
includes estimates for a potential offering. Please confirm that actual expense ratios are being
used as the basis for the data provided in the Summary of Fund Expenses section.
All data used for the Financial Highlights section is based on the average net assets for
the year ending December 31, 2010. The average net assets for The Gabelli Global Gold, Natural
Resources & Income Trust (the Fund) as of
June 9, 2011
Page 2
December 31, 2010 including preferred was $812,833,444.
The average net assets for the Fund as of December 31, 2010, excluding preferred was $713,941,269.
The
data provided in the Summary of Fund Expenses section is
based on the ending assets of $1,108,583,110 as
of February 2, 2011 plus an additional $750 million ($650 common and $100 million preferred) which
is the estimate for the potential offering. The total net assets used within the Summary of Fund
Expenses is $1,858,583,110. The net assets are broken down $1,659,690,935 common and
$198,892,175 preferred.
The expenses used in the Summary of Fund Expenses are based on the actual expenses reported
in the Funds December 31, 2010 Annual Report and have been adjusted to include the additional
expense estimates based on the potential offering. It should be noted that additional assets
raised in at the market offerings significantly increased
(by approximately $445 million)
the total net assets used in the
Summary of Fund Expenses versus the average net assets used in the Financial Highlights.
In addition, Dividends on Preferred Shares which is included in the Summary of Fund
Expenses is not an item listed within the Financial Highlights.
The Fund believes that the foregoing differences effectively account
for the differences in certain figures in the two tables noted by
the staff.
2. The Registration Statement covers common shares and preferred shares. However, the form of
prospectus supplement included in the Registration Statement covers only common shares. Please
include a form of prospectus supplement in the Registration Statement for the preferred shares.
A form of prospectus supplement relating to the preferred shares has been added to the
Registration Statement.
3. In the Statement of Additional Information, please move the Ownership of Shares in the Fund
section which currently appears on page 29, so that such section immediately follows the section
captioned Compensation Structure.
The Ownership of Shares in the Fund section has been moved accordingly.