October 6, 2005

Stephen H. Bier, Esq.
Dechert, L.L.P.
30 Rockefeller Plaza
New York, New York 10112-2200

Re:	Global High Income Dollar Fund
	File Nos. 33-127896 and 811-7540

Dear Mr. Bier:

	We have reviewed the registration statement on Form N-2 for
the
Global High Income Dollar Fund ("Fund"), registering additional
shares relating to a proposed issuance of non-transferable rights
to
Fund shareholders, filed with the Commission on August 26, 2005.
We
have the following comments.

Prospectus

Cover

		Please do not print entire paragraphs of disclosure only
in
capital letters, but employ the standard practice of using capital
and lower case letters.  To emphasize particular items of
disclosure,
please use bold-face type, italics or underlining.

Prospectus Summary

Use of Proceeds

	The disclosure in this section indicates the Fund may take
more
than one month to invest the proceeds of this offering.  If the
Fund
may take more than three months to invest the proceeds, please so
indicate, and disclose the reasons for the delay.  See Guide 1 to
Form N-2.

Investment Objectives and policies

   	The filing currently does not disclose the ratio of the
rights
offering.  Please note, when the information is completed, that
the
ratio of the offering may not exceed one new share for each three
rights held.  See Association of Publicly Traded Investment Funds
No
Action Letter, Ref. No. 85-299-CC (pub. avail. August 2, 1985).

	The disclosure does not indicate the extent to which the Fund
will invest 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 disclose that the advisor has a conflict of interest
with
respect to the rights offering because its fee, being asset-based,
will increase as a result of the offering.

	Please disclose the Fund`s anticipated average portfolio
duration and/or maturity.  Please also disclose the risks
attendant
with investing in securities of the stated duration or maturity.

	Has the Fund ever made a distribution which included a return
of
capital?  If so, please disclose the frequency and extent of the
returns of capital.

Risks Associated with Lower Rated Securities

	Please disclose that lower rated debt securities are also
known
as "junk."

Purpose of the Offering

	Since the Fund is non-diversified, please delete the
paragraph
titled "Additional Diversification."

	This section discusses a possible marginal reduction in the
Fund`s expense ration resulting from the increase in Fund assets
resulting from this offering.  Is this uncertain, insignificant
change in the expense ratio truly a "purpose of the offering?"
Please disclose the true purpose or purposes of the offering.

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 revise the disclosure accordingly.  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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