<SEC-DOCUMENT>0000000000-06-005928.txt : 20120827
<SEC-HEADER>0000000000-06-005928.hdr.sgml : 20120827
<ACCEPTANCE-DATETIME>20060202153800
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-06-005928
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20060202

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			Eaton Vance Tax-Managed Global Buy-Write Opportunities Fund
		CENTRAL INDEX KEY:			0001322435
		IRS NUMBER:				000000000

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		TWO INTERNATIONAL PLACE
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02110
		BUSINESS PHONE:		617-482-8260

	MAIL ADDRESS:	
		STREET 1:		TWO INTERNATIONAL PLACE
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02110
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>


May 10, 2005

Clair E. Pagnano, Esq.
Kirkpatrick & Lockhart Nicholson Graham, L.L.P.
75 State Street
Boston, Massachusetts 02109

Re:	Eaton Vance Tax-Managed Global Buy-Write Opportunities Fund
	File Nos. 333-123961 and 811-21745

Dear Ms. Pagnano:

	We have reviewed the registration statement on Form N-2 for
the
Eaton Vance Tax-Managed Global Buy-Write Opportunities Fund
("Fund")
filed with the Commission on April 8, 2005.  Based upon Securities
Act Release No. 6510 and the representations contained in your
letter
of April 8, 2005, we conducted a selective review of the
registration
statement.  We have the following comments.

Prospectus

Cover

	Please confirm that Eaton Vance will not recoup from the Fund
any offering or organization cost reimbursements it makes to the
Fund.  Please include the reimbursement agreement as an exhibit to
the registration statement.

	Please indicate that the Fund will obtain current income
primarily from short-term gains, some of which will not receive
qualified dividend status.  Also, please make more prominent the
disclosure that the Fund will seek to generate current earnings
from
option premiums and, to a lesser extent, from dividends on stocks
held.

	Please confirm that the disclosure of the Fund`s lack of
trading
history and attendant risks, and all remaining disclosure required
by
Item 1.1.i. of Form N-2 will appear on the outside front cover
page
and will be prominent.  See Item 1.1.i. of Form N-2.

	Please delete the disclosure to the effect that the
prospectus
is accurate only as of its effective date, or, as an alternative,
disclose that the Fund will notify investors promptly of any
material
changes.






Summary

Investment Objectives and Strategies

	The disclosure indicates the Fund will invest at least 35% of
assets in foreign securities.  The staff takes the position that a
"Global" fund must invest in a manner consistent with that term by
investing substantially, i.e., at least 50% of assets, in a number
of
foreign countries around the globe.  Please revise the disclosure
accordingly.

	Please summarize the criteria the Adviser and Sub-Adviser
will
use to select stocks for the Fund`s portfolio.

	Does the Fund have an opinion of tax counsel?  If so, please
file as an exhibit to the registration statement.

	Disclosure in this section indicates the Fund will hold
portfolios of stocks "similar to" the indexes on which the Fund
will
write call options.  Please explain supplementally whether this
"similarity" will have the effect of making these positions
straddles?

	Please disclose the range of capitalizations for the S&P
MidCap
400 Index.

	Will the Fund have a portfolio turnover rate in excess of
100%?
If so, please disclose in the Summary that the Fund expects to
maintain a high turnover rate and summarize the attendant risks.

Investment Objectives, Policies and Risks

	Please confirm that the Fund has no intention to use leverage
within the first 12 months after this registration statement
becomes
effective.

Temporary Investments

	Please clarify that, under unusual market circumstances, the
Fund may invest temporarily in cash or cash equivalents, which may
not be in furtherance of the Fund`s investment objective.

Illiquid Securities

	Please disclose the likely percentage range of the Fund`s
investments in illiquid securities.





Underwriting

	The disclosure indicates the Fund has agreed not to offer,
sell
or register any additional equity securities, other than common
shares, for 180 days after the date of the
underwriting agreement without the prior written consent of the
Representatives.  Please advise us supplementally whether the
Fund`s
Board considered this to be in the shareholders` best interest
and,
if so, why.

	Did the Fund`s Board consider the fee arrangement between the
Adviser and qualifying underwriters when approving the Advisory
Agreement?  Please indicate what services are provided pursuant to
the fee agreement.  Clarify whether the services are for
distribution
and therefore subject to the NASD sales load cap.  Please file the
agreement as an exhibit to the registration statement.

	Please advise whether the NASD has reviewed and approved the
terms of the underwriting agreement.

	Please insert a heading "Additional Compensation to
Underwriters" before the paragraph describing the additional
compensation agreement between Eaton Vance and certain qualifying
underwriters.  Also, please clarify that the additional
compensation
payable to the underwriters, together with all other compensation
payable to the underwriters, will not exceed the designated
percentage of the aggregate initial offering price of the Common
shares offered.  Finally, please include the additional
compensation
in the table on the front cover of the prospectus.

Statement of Additional Information

Approval of Investment Advisory Agreement
	This disclosure does not contain a reasonably detailed
discussion of the material factors that formed the basis for the
Board of directors approving the investment advisory contract.
Please include this information in the disclosure.  See
Instruction
to Item 18.13 of Form N-2.
Closing
      We note that portions of the filing are incomplete. We may
have
additional comments on such portions when you complete them in a
pre-
effective amendment, on disclosures made in response to this
letter,
on information supplied supplementally, or on exhibits added in
any
pre-effective amendments.  Please note that comments we give in
one
section apply to other sections in the filing that contain the
same
or similar disclosure.
      Please advise us if you have submitted or expect to submit
an
exemptive application or no-action request in connection with your
registration statement.

   	Please inform the staff of the information the Fund proposes
to
omit from the final pre-effective amendment pursuant to Rule 430A
under the Securities Act.
      Response to this letter should be in the form of a pre-
effective amendment filed pursuant to Rule 472 under the
Securities
Act. Where no change will be made in the filing in response to a
comment, please indicate this fact in a supplemental letter and
briefly state the basis for your position.
      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the Fund and its management are in
possession of all facts relating to the Fund`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
	Notwithstanding our comments, in the event the Fund requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that
* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* the Fund may not assert this action as defense in any proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.
      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Investment Management in connection with our review of
your filing or in response to our comments on your filing.

	Any questions you may have regarding the filing or this
letter
may be directed to me at 202.551.6965.


							Sincerely,


							Vincent J. Di Stefano
							Senior Counsel

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</DOCUMENT>
</SEC-DOCUMENT>
