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[LETTERHEAD]

August 26, 2004

VIA EDGAR

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

      Re:  Global High Income Dollar Fund Inc.
           Investment Company Act File No. 811-7540
           Registration Statement on Form N-2

Ladies and Gentlemen:

Electronically transmitted for filing on behalf of the Global High Income Dollar
Fund Inc. (the "Fund") is the Fund's initial registration statement under the
Securities Act of 1933, as amended (the "1933 Act") and Amendment No. 8 to the
Fund's registration statement under the Investment Company Act of 1940, as
amended (the "1940 Act") on Form N-2 (the "Registration Statement"). The
Registration Statement relates to a proposed issuance of non-transferable rights
to Fund shareholders entitling them to subscribe for Fund shares to be
registered pursuant to the Registration Statement.

Certain items contained in the Registration Statement, including exhibits
thereto, will be completed and filed in a pre-effective amendment to the
Registration Statement.

Filing fees required under the 1933 Act have been transmitted to the SEC's
lockbox.  Please direct any questions concerning the filing to my attention at
212.698.3889.

Very truly yours,


/s/ Stephen H. Bier
Stephen H. Bier


Law Offices of Dechert LLP
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