December 23, 2019

James Longshore
Chief Executive Officer
Xtra-Gold Resources Corp.
Village Road Plaza, Suite 2150
P.O. Box AP 59217
Nassau
Bahamas

       Re: Xtra-Gold Resources Corp.
           Form 20-F/A for the Fiscal Year Ended December 31, 2018
           Filed July 31, 2019
           File No. 333-139037

Dear Mr. Longshore:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 20-F/A for the Fiscal Year Ended December 31, 2018

Item 4 Information on Xtra-Gold, page 16

1.    We note your disclosure of indicated and inferred mineral resources. Only
proven and
      probable reserves may be disclosed in filings with the United States
Securities and
      Exchange Commission pursuant to the Instructions to paragraph (b)(5) of
Industry Guide
      7. Please revise to remove the mineral resources disclosure or tell us
why you do not
      believe it is necessary to do so.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact John Coleman at 202-551-3610 or Ethan Horowitz at
202-551-3311 if
 James Longshore
Xtra-Gold Resources Corp.
December 23, 2019
Page 2

you have questions regarding the comments.



FirstName LastNameJames Longshore            Sincerely,
Comapany NameXtra-Gold Resources Corp.
                                             Division of Corporation Finance
December 23, 2019 Page 2                     Office of Energy & Transportation
FirstName LastName