March 31, 2025

VIA EDGAR

Mr. Kenneth Ellington

U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review and Accounting Office

New York Regional Office

100 Pearl Street, Suite 20-100

New York, NY 10004-2616

Dear Mr. Ellington,

This letter is in response to the comments you provided telephonically to Lisa Henry of Ropes & Gray LLP on March 3, 2025 with respect to the Forms N-CSR and Forms N-CEN filed by the series of the Registrants listed on Appendix A attached hereto (each, a “Fund” and collectively, the “Funds”) for the fiscal periods ended May 31, 2024, July 31, 2024, and October 31, 2024. The comments and Registrants’ responses thereto are set forth below. Changes referenced in responses below will be incorporated into Forms N-CSR and Forms N-CEN and other applicable regulatory filings going forward, as noted below.

Comments and Responses

Response: The footnote to the schedule of investments that identifies Level 3 securities also includes a reference to the Fair Value Measurements Note to the Financial Statements, which includes a description of the inputs for Level 1, Level 2 and Level 3 securities. Each Registrant believes that this disclosure meets the requirements of Article 12-12 footnote 9 of Regulation S-X.

Response: For Funds with multiple contracts within the senior loan facility for which a weighted average interest rate at period-end has been presented, the Registrants will replace the weighted average interest rate with the range of interest rates in effect at period-end, with appropriate disclosure of the related index and spread associated with such range.

Response: For the fiscal year ended October 31, 2024, the tax reclaims receivables reflected in Eaton Vance Global Income Builder Fund’s Statement of Assets and Liabilities represent withholding tax reclaims primarily from France, Germany and Switzerland. For the fiscal year ended October 31, 2024, the tax reclaims receivables reflected in Eaton Vance Global Equity Income Fund’s Statement of Assets and Liabilities represent withholding tax reclaims primarily from Germany and Switzerland. Each Fund’s custodian, State Street Bank and Trust Company (the “Custodian”), files the statutory reclaims as directed by each Fund’s administrator, Eaton Vance Management (the “Administrator”). The Administrator reviews open reclaims with the Custodian’s tax reclaim specialists no less frequently than monthly to ensure that all relevant documentation has been filed and that the reclaims are in process.

Response: Items 4(i) and 4(j) were inadvertently omitted from the Form N-CSR filing for Eaton Vance Floating-Rate Income Trust, although not applicable. The Registrant will add the requested disclosure in future filings.

Response: The Registrant confirms that Eaton Vance Emerging Markets Debt Opportunities Fund complied with the shareholder notice requirements regarding its return of capital per Section 19(a) of the Investment Company Act of 1940.

Response: The Registrant notes that the International (Cayman Islands) Floating Rate Income Portfolio does not have an SEC file number and, accordingly, none was included in Item C.20.a.iv of Form N-CEN.

* * *

* * *

If you have any questions or comments concerning the foregoing, please contact the undersigned at 617-951-7780.

Very truly yours,

/s/ Lisa Henry

cc: Sarah Clinton, Ropes & Gray LLP

Stephanie Rosander, Eaton Vance Management

Appendix A