Form: N-2/A

Initial filing of a registration statement on Form N-2 for closed-end investment companies

May 12, 2004

OPINION AND CONSENT OF COUNSEL

Published on May 12, 2004

Exhibit (l)

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

May 12, 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 1,745,315 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 a registration
statement, filed by the Corporation with the U.S. Securities and Exchange
Commission (the "Commission") on Form N-2, Securities Act File Nos. 333-111045
and Investment Company Act No. 811-08025, Pre-Effective Amendment No. 1 thereto
filed by the Corporation with the Commission on February 27, 2004, and
Pre-Effective Amendment No. 2 thereto filed by the Corporation with the
Commission on May 12, 2004 (as so amended, the "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 by the Corporation with the
Commission as an exhibit to the Registration Statement.

Sincerely,

/s/ Stephanie A. Djinis
Stephanie A. Djinis