GAMCO Global Gold, Natural Resources & Income Trust

Regulatory Filings • Feb 10, 2010

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NEW YORK 10036-6522

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(212) 735-3000

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DIRECT DIAL

212-735-2262

EMAIL ADDRESS

Rose.Park@SKADDEN.COM

February 10, 2010

Ms. Laura E. Hatch

Staff Accountant

Division of Investment Management

Securities and Exchange Commission

Washington, D.C. 20549

RE:
(File
Nos. 333-164363, 811-21698)

Dear Ms. Hatch:

The Gabelli Global Gold, Natural Resources and Income Trust (the "Fund") has authorized us to make the following responses to the comments in your letter dated February 1, 2010 to its Registration Statement on Form N-2 (the "Registration Statement"), and to your follow-up comments regarding Item No. 7 in such letter provided to us via telephone on February 9, 2010. Your comments are set forth below and our response follows each respective comment in italics.

Form N-CSR

Statement of Assets and Liabilities

| 7. |
| --- |
| The
Fund commenced offering common shares from its existing 3 year shelf
registration on February 19, 2009. |
| As
per Section 8.248.26 of the 2009 AICPA Investment Companies Audit and
Accounting Guide and discussed by paragraphs 5-6 of FASB ASC 946-20-25 and
946-20-35-5, offering costs of closed-end funds with a continuous offering
period should be accounted for as a deferred charge until operations begin
and thereafter amortized to expense over twelve months on a straight-line
basis. |
| In
accordance with GAAP, prior to February 19, 2009, The Gabelli Global Gold,
Natural Resources & Income Trust treated the $164,666 relating to
offering expenses as a deferred charge. As of February 19,
2009, when The Gabelli Global Gold, Natural Resources & Income Trust
commenced offering common shares, the shelf offering costs associated with
the issuance of common shares have been amortized to expense over the
remaining twelve months on a straight-line basis. |
| The
Fund’s Semi-Annual Report dated June 30, 2009 listed the offering costs in
the Fund’s Statement of Changes in Net Asset within the subheading “Fund
Share Transactions,” under the guidance that offering costs of closed-end
funds should be charged to paid-in capital. Subsequent to
the issuance of the June 30 financial statement, it was determined that
the Fund’s offering was a continuous offering that necessitated a
different accounting treatment under GAAP, which was to record the
offering expenses as a deferred charge to be amortized over twelve months
on a straight-line basis. |
| The
effect of the change in accounting treatment on the Fund’s net asset value
in dollars and on a per share basis was de minimis. As of
December 31, 2009, the accounting treatment conforms with
GAAP. |

If you have any questions or comments or require any additional information in connection with the Registration Statement, please telephone me at (212) 735-2262.

Sincerely,
/s/
Rose Park