United States securities and exchange commission logo January 19, 2022 William Rhind Chief Executive Officer and Chief Financial Officer GraniteShares Gold Trust c/o GraniteShares LLC 205 Hudson Street, 7th floor New York, NY 10013 Re: GraniteShares Gold Trust Form 10-K for Fiscal Year Ended June 30, 2021 Filed on August 13, 2021 File No. 001-38195 Dear Mr. Rhind: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment apply to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for Fiscal Year Ended June 30, 2021 Report of Independent Registered Public Accounting Firm, page F-2 1. We note that your independent accountant's report only opines on the financial statements as of and for the years ended June 30, 2021 and 2020, and refers to an other auditors report on the financial statements as of June 30, 2019. However, we note that the other auditors report is not included in your filing. Please amend your filing to include an audit report of your former independent registered public accounting firm to comply with the requirements of Rule 2-05 of Regulation S-X. In closing, 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. William Rhind GraniteShares Gold Trust January 19, 2022 Page 2 You may contact Becky Chow, Staff Accountant, at (202) 551-6524, or John Spitz, Staff Accountant, at (202) 551-3484 with any questions. FirstName LastNameWilliam Rhind Sincerely, Comapany NameGraniteShares Gold Trust Division of Corporation Finance January 19, 2022 Page 2 Office of Finance FirstName LastName