<SEC-DOCUMENT>0000000000-07-060890.txt : 20120808
<SEC-HEADER>0000000000-07-060890.hdr.sgml : 20120808
<ACCEPTANCE-DATETIME>20071217125210
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-07-060890
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20071217

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			GABELLI GLOBAL UTILITY & INCOME TRUST
		CENTRAL INDEX KEY:			0001282957
		IRS NUMBER:				320116828
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		ONE CORPORATE CENTER
		CITY:			RYE
		STATE:			NY
		ZIP:			10580
		BUSINESS PHONE:		8149219105

	MAIL ADDRESS:	
		STREET 1:		ONE CORPORATE CENTER
		CITY:			RYE
		STATE:			NY
		ZIP:			10580
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>




								December 17, 2007


Gary Rawitz, Esq.
Paul, Hastings, Janofsky & Walker LLP
75 East 55th Street
New York, NY 10022


      RE:	Gabelli Global Utility & Income Trust
      333-147575; 811-21529

Dear Mr. Rawitz:

	We have reviewed the registration statement on Form N-2 for
the
Gabelli Global Utility & Income Trust, filed with the Securities
and
Exchange Commission on November 21, 2007.  We have the following
comments:


PROSPECTUS


Cover Page

1. The disclosure states that "under normal market conditions, the
Fund invests at least 80% of its assets in equity securities of
domestic and foreign companies involved in the "utilities
industry"
and other industries that are expected to periodically pay
dividends."  Please state whether or not the Fund`s 80% policy is
fundamental.  In addition, if the policy is not fundamental,
please
state that shareholders will be notified if the Fund changes its
policy.

Prospectus Summary

2. Under the heading "Investment Objectives and Policies," the
disclosure states that the Fund will invest in "equity securities
(including preferred securities) of domestic and foreign
companies."
Please state generally the types of equity securities in which the
Fund may invest.

3. Under the heading "Dividends and Distributions," the disclosure
states that "for the fiscal year ended December 31, 2006, the Fund
made distributions of $1.20 per common share, none of which
constituted a return of capital."  For the fiscal year ending
December 31, 2007, is it also expected that none of the Fund`s
distributions will constitute a return of capital?

4. Under the heading "Exchange Listing," the disclosure states
that
"any series of Fixed Rate Preferred Shares issued by the Fund
would
also likely be listed on the Amex."  Please state whether or not
any
series of Variable Rate Preferred Shares issued by the Fund would
likely be listed on an exchange.

5. Under the heading "Management and Fees," the disclosure states
"the Fund`s total return on the net asset value of the common
shares
will be monitored on a monthly basis to assess whether the total
return on the net asset value of the common shares exceeds the
stated
dividend rate or corresponding swap rate of each particular series
of
preferred shares for the period."  Please make clear how the
"corresponding swap rate" will be determined.

6. Under the heading "Repurchase of Common Shares," the disclosure
states that "the Fund`s Board has authorized the Fund to
repurchase
its common shares in the open market when the common shares are
trading at a discount of 10% or more from net asset value."
Please
make it clear whether the Fund will repurchase its common shares
in
the open market when the common shares are trading at a discount
of
10% or whether the Fund reserves the freedom of action to
repurchase
its common shares.  In addition, please discuss how much of the
outstanding common shares the Fund will repurchase (i.e., until
the
discount falls to x%).

Financial Highlights

7. The same footnote symbol ("****") is used for the total
investment
return for the period ended December 31, 2004 as well as the
portfolio turnover rate for the year ended December 31, 2006 and
the
six months ended June 30, 2007.  It appears that the footnote
corresponds to the total return for the period ended December 31,
2004.  Please use a different symbol for the portfolio turnover
rate
and include a corresponding footnote.

Investment Objectives and Policies

8. The disclosure states that "the Fund expects to generally be
invested in securities of issuers located in at least three
countries
including the U.S. and possibly including developing countries.
The
Fund currently anticipates that its investment strategy will cause
it
to invest approximately 30% of its assets in approximately 11
countries throughout the world."  Please clarify whether or not
"11
countries throughout the world" includes the U.S.




STATEMENT OF ADDITIONAL INFORMATION

Ownership of Shares in the Fund

9. Please move the information under this heading from the section
titled "Portfolio Holdings Information" to the section titled
"Portfolio Manager Information."


GENERAL

10. 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.
11. If you intend to omit certain information from the form of
prospectus included with the registration statement that is
declared
effective in reliance on Rule 430A under the Securities Act,
please
identify the omitted information to us supplementally, preferable
before filing the Fund`s final pre-effective amendment.
12. 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.


TANDY LETTER

   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, please furnish a letter
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.

   We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.


			*		*		*		*
     If you have any questions about these comments, please call
me
at 202-551-6957.

								Sincerely,



								Laura E. Hatch
								Staff Accountant
</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
