OPINION OF COUNSEL

Published on February 27, 2004

EXHIBIT 99.2(l)

Law Offices of Stephanie A. Djinis
1749 Old Meadow Road
Suite 310
McLean, Virginia 22102

February 26, 2004

Global Income Fund, Inc.
11 Hanover Square
New York, New York 10005

Re: Global Income Fund, Inc.
File Nos. 333-111045 and 811-08025

Dear Sir or Madam:

Global Income Fund, Inc. (the "Corporation") is a corporation organized
under the laws of the State of Maryland by Articles of Incorporation, as
amended, restated and supplemented. You have requested our opinion as to certain
matters regarding the issuance of certain Shares of the Corporation. As used in
this letter, the term "Shares" means up to 1,739,185 of additional shares of
common stock of the Corporation, par value $.01 per share, that may be issued
pursuant to the Fund's rights offering as described in its registration
statement filed with the U.S. Securities and Exchange Commission on Form N-2,
Securities Act File Nos. 333-111045 and Investment Company Act No. 811-08025
("Registration Statement").

We have, as counsel, participated in various corporate and other
matters relating to the Corporation. We have examined copies of the
Corporation's Articles of Incorporation, as amended, restated and supplemented,
the Corporation's By-laws, as amended, and other documents relating to the
operation of the Corporation, either certified or otherwise proven to our
satisfaction to be genuine, and we are generally familiar with its business
affairs. Based upon the foregoing, it is our opinion that, when sold in
accordance with the Articles of Incorporation, By-laws and the terms
contemplated by the Registration Statement, the Shares will be legally issued,
fully paid and nonassessable by the Corporation.

We hereby consent to the filing of this opinion in connection with
Pre-Effective Amendment No. 1 to the Registration Statement being filed with the
Securities and Exchange Commission.

Sincerely,

/s/ Stephanie A. Djinis
Stephanie A. Djinis