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GAMCO Global Gold, Natural Resources & Income Trust

Regulatory Filings Nov 18, 2010

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Skadden, Arps, Slate, Meagher & Flom llp

FOUR TIMES SQUARE NEW YORK 10036-6522

TEL: (212) 735-3000 FAX: (212) 735-2000 www.skadden.com

DIRECT DIAL 212-735-3859

EMAIL ADDRESS [email protected]

November 18, 2010

FIRM/AFFILIATE OFFICES

BOSTON CHICAGO HOUSTON LOS ANGELES PALO ALTO SAN FRANCISCO WASHINGTON, D.C. WILMINGTON

BEIJING BRUSSELS FRANKFURT HONG KONG LONDON MOSCOW MUNICH PARIS SÃO PAULO SHANGHAI SINGAPORE SYDNEY TOKYO TORONTO VIENNA

VIA EDGAR Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549

RE: The Gabelli Global Gold, Natural Resources & Income Trust Shelf Registration Statement of Form N-2 (File No. 811-21698)

Ladies and Gentlemen:

Electronically transmitted herewith for filing on behalf of The Gabelli Global Gold, Natural Resources & Income Trust (the “ Fund ”) is the Fund’s shelf registration statement on Form N-2 (the “ Registration Statement ”) under the Securities Act of 1933. Pursuant to Rule 415(a)(6), the Registration Statement, upon effectiveness, is intended to replace the Fund’s current shelf registration statement (File Nos. 333-164363 and 811-21698) (the “ Current Shelf ”).

The Fund represents that its Registration Statement is substantially similar to Post-Effective Amendment No. 2, filed April 8, 2010, to the Fund’s Current Shelf and that no substantive changes have been made to the disclosure contained in Post-Effective Amendment No. 2 to the Fund’s Current Shelf, except as follows:

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| o | The cover page was revised to include disclosure concerning shareholder access to the
Fund’s annual and semi-annual reports and Statement of Additional Information on the
Fund’s website. |
| --- | --- |
| o | The Fund’s financial information (including its financial statements, pro-forma
financial statements and MD&A disclosure) was updated to include data as of June 30, 2010
and is substantially identical to the financial information contained in the Fund’s most
recent prospectus supplement filed on September 30, 2010 (such prospectus supplement was
filed pursuant to the Current Shelf). |
| o | The Risk Factors section was revised to address current
market conditions and current geopolitical events. |
| o | The Description of the Shares section was updated to include a table summarizing the
Fund’s outstanding securities. |
| o | The Management sections in the prospectus and in the Statement of Additional
Information were revised, as appropriate, to include disclosure relating to the
calculation of the Fund’s weekly net assets upon which the investment adviser’s fee is
based, to update the investment adviser’s assets under management, to describe the
investment adviser’s responsibilities under the investment advisory agreement, to provide
updated information regarding the Fund’s portfolio managers and to update the name of the
Fund’s sub-administrator. |
| o | The Issuance of Common Stock section was updated with data as of September 30, 2010. |
| o | The Regulatory Matters section was updated to show the Fund’s current legal
proceedings. |
| o | The Net Asset Value section was revised to elaborate upon how the net asset value of
the Fund’s shares is calculated. |
| o | A Limitation of Trustees’ and Officer’s Liability section was added to the
prospectus. It replicates what was and remains in the Fund’s Statement of Additional
Information. |
| o | The form of prospectus supplement was updated with disclosure relating to shareholder
access to the Fund’s annual and semi-annual reports and Statement of Additional
Information on the Fund’s website, to include data for the Price Range of Common Shares
through the most recent fiscal quarter and to include Capitalization, Financial Highlights
and Plan of Distribution sections. |
| o | The Management section in the Statement of Additional Information was further revised
to include disclosure regarding the number of meetings each Board of Trustees committee
held during the last fiscal year and to provide minor updates to the Trustees’
biographies. |
| o | The tax disclosure was revised to show current regulatory conditions. |
| o | Part C of the Registration Statement was amended to
reflect facts as they relate to the Registration Statement and to
comply with the requirements of Form N-2. |
| o | Other minor factual updates. |

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As such, the Fund hereby requests expedited review of the Fund’s Registration Statement.

If you have any questions or comments or require any additional information in connection with the Fund or the Registration Statement please telephone me at (212) 735-3859 or Richard Prins at 212-735-2790.

Very truly yours,
/s/ Veronica Castillo
Veronica Castillo, Esq.

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