UNITED STATES
SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM N-CSRS/A

CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT
INVESTMENT COMPANIES

ING Clarion Global Real Estate Income Fund

(Exact name of registrant as specified in charter)

201 King of Prussia Road
Radnor, PA 19087

T. Ritson Ferguson, President and Chief Executive Officer
ING Clarion Global Real Estate Income Fund
201 King of Prussia Road
Radnor, PA 19087

Registrant’s telephone number, including area code: 1-888-711-4272

Date of fiscal year end: December 31

Date of reporting period: June 30, 2009

Form N-CSR is to be used by management investment companies to file reports with the Commission not later than 10 days after the transmission to stockholders of any report that is required to be transmitted to stockholders under Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1). The Commission may use the information provided on Form N-CSR in its regulatory, disclosure review, inspection, and policymaking roles.

A registrant is required to disclose the information specified by Form N-CSR, and the Commission will make this information public. A registrant is not required to respond to the collection of information contained in Form N-CSR unless the Form displays a currently valid Office of Management and Budget (“OMB”) control number. Please direct comments concerning the accuracy of the information collection burden estimate and any suggestions for reducing the burden to Secretary, Securities and Exchange Commission, 450 Fifth Street, NW, Washington, DC 20549-0609. The OMB has reviewed this collection of information under the clearance requirements of 44 U.S.C. § 3507.

 

 

Item 1. Report(s) to Stockholders.

The Trust’s semi-annual report transmitted to shareholders pursuant to Rule 30e-1 under the Investment Company Act of 1940 is as follows:

 

 

 

ING Clarion Global Real Estate Income Fund (‘the Fund”), acting in accordance with an exemptive order received from the Securities and Exchange Commission (‘SEC”) and with approval of its Board of Trustees (the “Board”), has adopted a managed distribution policy (the “Policy”) with the purpose of distributing over the course of each year, through periodic distributions as nearly equal as practicable and any required special distributions, an amount closely approximating the total taxable income of the Fund during such year and all of the returns of capital paid by portfolio companies to the Fund during such year. In accordance with its Policy, the Fund distributes a fixed amount per common share, currently $0.045, each month to its common shareholders. This amount is subject to change from time to time in the discretion of the Board. Although the level of distributions is independent of fund performance, the Fund expects such distributions to correlate with its performance over time. Each monthly distribution to shareholder is expected to be at the fixed amount established by the Board, except for extraordinary distributions and potential increases or decreases in the final dividend periods for each year in light of the Fund’s performance for the entire calendar year and to enable the Fund to comply with the distribution requirements imposed by the Internal Revenue Code. Over time, the Fund expects that the distribution rate in relation to the Fund’s Net Asset Value (“NAV”) will approximately equal the Fund’s total return on NAV.

 

The fixed amount of distributions will be reviewed and amended as necessary by the Board at regular intervals with consideration of the level of investment income and realized gains. The Board strives to establish a level regular distribution that will meet the Fund’s requirement to pay out all taxable income (including amounts representing return of capital paid by portfolio companies) with a minimum of special distributions. The Fund’s total return in relation to changes in NAV) is presented in the financial highlights table. Shareholders should not draw any conclusions about the Fund’s investment performance from the amount of the current distribution or from the terms of the Fund’s managed distribution policy. The Board may amend or terminate the managed distribution policy without prior notice to Fund shareholders.

 

Shareholders should note that the Fund’s Policy is subject to change or termination as a result of many factors. The Fund is subject to risks through ownership of its portfolio company holdings including, but not limited to, declines in the value of real estate held by the portfolio company, risks related to general and local economic conditions, and portfolio company losses. Moreover, an economic downturn could have a material adverse effect on the real estate markets and on real estate companies in which the Fund invests, which in turn could result in the Fund not achieving its investment or distribution objectives thereby jeopardizing the continuance of the Policy. Please refer to the prospectus for a fuller description of the Fund’s risks.

ING Clarion Global Real Estate Income Fund

Letter to Shareholders ï

 

Dear Shareholder:

 

We are pleased to deliver the 2009 semi-annual report for the ING Clarion Global Real Estate Income Fund (the “Fund”).

 

Performance Review

 

Global real estate stocks are up slightly for the year after a volatile swing. The year began with a continuation of their sell-off which began in 2007, as global real estate stocks fell approximately 30% in the first two and a half months. However, in early March real estate stocks reached lows that we believe will prove to be the bottom of the most significant bear market for real estate stocks in history. Real estate stocks rallied for four months beginning in mid-March recording some significant gains in the second quarter, and recouped the first quarter losses to finish slightly positive for the year-to-date period, but still way below peak valuations of 2007. The performance of the Fund has also been volatile, though it may have been worse if not for the decision to eliminate the leverage used by the fund at the beginning of the year. The Fund’s Net Asset Value (“NAV”) rose slightly (+2.8%) for the first half of 2009. The Fund’s market price return (i.e., stock price appreciation plus dividends) was significantly more positive (+30.6%) through the first six months driven by the dividend and a significant improvement in the fund share price which improved from a –29% discount to NAV at year-end to a more modest –11% discount as of June 30th. The Fund’s market price closed at $4.85 and the NAV per share was $5.47 on June 30th.

 

During the first six months of 2009 the S&P Developed Property Index (S&PDPI)⁽¹⁾ gained 5.6% and the Morgan Stanley REIT Preferred Index (MSRPI)⁽²⁾ rose 22.1%. A blended benchmark of 80% S&PWPI and 20% MSRPI rose 8.96% in the first six months of 2009. Our common stock positions, which comprised about 66% of the portfolio thus far in 2009, rose an average of 0.9% which trailed the 5.6% return on the S&PDPI. Our preferred stock positions averaged 23% of the portfolio during the first half and the average 23.9% gain on our preferred stock position outperformed the MSRPI return for the period. Despite an overweight to preferred stocks and our good security selection within the allocation, the fund underperformed due to an underweighting of the Asia-Pacific common stock which generally offer low yields but during the period delivered some of the best total returns.

 

The Fund paid total dividends of $0.27 per share for the first 6 months of 2009 consisting of six regular monthly dividends of $0.045 per share. The annualized dividend of $0.54 per share represents a 11.1% yield on share price and a 9.9% yield on NAV. The board has continued to review the sustainability of our regular monthly dividend in light of the substantial dividends that have been paid out over the last two years and the difficult market environment. Based on income and realized gains to date, the board has thus far seen fit to maintain the monthly dividend at the same level rate.

 

The board of directors has decided to pursue a merger of the fund with the ING Clarion Real Estate Income Fund (NYSE: IIA), a smaller closed end fund with good yield characteristics from a portfolio of common and preferred stocks issued by U.S. real estate companies. If approved by IIA shareholders later this year, the merger offers an opportunity to improve the yield of the existing portfolio, some slight improvement of the expense ratios per share as the fund would spread fixed costs over a larger portfolio. The structure of the acquisition is proposed as a share for share acquisition on a basis which would ensure that there is no dilution of value per share.

 

Semi-Annual Report ï June 30, 2009 ï 1

ING Clarion Global Real Estate Income Fund ï Letter to Shareholders continued

 

Portfolio Review

 

The Fund’s investments remain well-diversified by property type and geography as shown in the pie charts below. After some fairly significant changes last year, the geographic mix of the portfolio has been fairly stable during the past 12 months. At June 30th, the Fund’s portfolio was 37% in the North America, 17% in Europe, 20% in Asia-Pacific, with 26% in preferred stock of real estate companies. Retail is the largest property type represented in the portfolio at 37%. Retail properties have historically shown more stable cash flows during economic slow-downs than other commercial property types.

 

 

 

In February and March, the Fund completed the full retirement of the last outstanding preferred stock ($370 Million). At the end of the second quarter the Fund had only modest leverage of less than 4% consisting of borrowings on our line of credit which has a very low interest rate and can be easily repaid.

 

Market Commentary

 

Capital raising progress could be a stimulus for continued good performance. Real estate companies have raised over $33 billion of equity over the past nine months, with the majority of this activity occurring over the past four months. The U.S., Australia, the U.K. and Singapore account for more than 90% of the aggregate equity raised as companies have moved quickly to repair balance sheets as the equity “window” remains open.

 

The downside of balance sheet repair is earnings dilution. Equity raises have been a double-edged sword in many cases, with the good news of fresh capital and improved balance sheets offset by the bad news of dilution to earnings per share. The countries with the greatest equity raising activity have seen the most dramatic negative revisions to earnings growth including the U.K., Australia, Singapore and the U.S. The change in the earnings growth forecast for this year and next versus our forecast at the beginning of the year has been overwhelmingly due to the capital raising impact as opposed to revisions to occupancy and rent forecasts, which have remained relatively stable.

 

Real estate companies are conserving more cash through other measures, too. Additional capital has been sourced via combinations of a reduction in payout policies (dividend cuts), access to the secured and unsecured debt markets, and successful refinancing of existing secured debt. While not an overall panacea, these capital raising activities constitute a critical but necessary step in preparing property companies for the latter stages of a recession which should begin to present an increasing number of potential attractive investment opportunities.

 

Debt maturities are a diminishing issue for listed real estate companies. Despite continuing challenging market conditions, debt is available to well-capitalized borrowers on reasonable terms. The environment has changed dramatically in just a few months. For example, Simon Property Group (SPG) issued $650 million of unsecured 10-year debt in March at a 10.35% coupon with a 10.75% yield to maturity. Only two months later, SPG raised an additional $600 million of 5-year debt at a 6.75% coupon and a 7.0% yield to maturity. The ability to source new equity through stock offerings, new debt (both secured and unsecured) and cash flow retention has allowed many listed real estate companies to deal with looming maturities over the next few years. The weighted average leverage for public real estate companies now stands at 45%, down from a peak of 51% at the end of February.

 

2 ï Semi-Annual Report ï June 30, 2009

ING Clarion Global Real Estate Income Fund ï Letter to Shareholders continued

 

Debt maturities are an industry-wide issue that is likely to create opportunities for REITs in the next few years. According to research from Deutsche Bank, and highlighted in the following chart, in the U.S. alone approximately $200 to $300 billion of commercial real estate loans will come due each year from 2009 to 2013. This includes between $19 to $75 billion of CMBS maturities each year. While many of these loans are expected to be extended, it is very likely that some properties will be brought to market because of the inability of borrowers to find adequate funding from new lenders or new equity investors to take out maturing loans. This trend could lead to an increase in properties brought to market. For those with capital, including the better-capitalized listed property companies, “one person’s problem is another person’s opportunity.”

 

Real estate stocks continue to offer attractive valuations for long-term investors. Even after the strong gains in the second quarter, real estate stocks are trading only slightly ahead of the depressed valuations seen at the end of 2008, the worst year for real estate stocks’ returns in history. We remain cautiously optimistic about the total return potential for listed real estate company stocks despite the continuing challenges of the economic environment and the resultant weak real estate fundamentals. Real estate stocks are well ahead of private market real estate in terms of valuation adjustments. REITs are trading at values that reflect a 15% gap to private market indices, already reflecting a 30% decline in gross asset values, which has been reflected in our internally-generated NAVs.

 

Given current market conditions we remain overweight quality companies, with a bias towards “relative value” where companies with balance sheet issues are excessively discounted by the market. We believe the Fund remains well positioned to meet its primary objective of delivering a high level of stable monthly income as well as its secondary objective of capital appreciation.

 

We appreciate your continued faith and confidence.

 

Sincerely,

 

 

The views expressed represent the opinion of ING Clarion Real Estate Securities and are subject to change and are not intended as a forecast or guarantee of future results. This material is for informational purposes only, does not constitute investment advice, and is not intended as an endorsement of any specific investment. Information and opinions are derived from proprietary and non-proprietary sources.

Semi-Annual Report ï June 30, 2009 ï 3

ING Clarion Global Real Estate Income Fund

Portfolio of Investments ï June 30, 2009 (unaudited)

 

 

See notes to financial statements.

4 ï Semi-Annual Report ï June 30, 2009

ING Clarion Global Real Estate Income Fund ï Portfolio of Investments continued

 

 

 

 

 

See notes to financial statements.

Semi-Annual Report ï June 30, 2009 ï 5

ING Clarion Global Real Estate Income Fund

Statement of Assets and Liabilities ï June 30, 2009 (unaudited)

 

 

See notes to financial statements.

6 ï Semi-Annual Report ï June 30, 2009

ING Clarion Global Real Estate Income Fund

Statement of Operations ï For the Six Months Ended June 30, 2009 (unaudited)

 

 

See notes to financial statements.

Semi-Annual Report ï June 30, 2009 ï 7

ING Clarion Global Real Estate Income Fund

Statements of Changes in Net Assets ï

 

 

 

See notes to financial statements.

8 ï Semi-Annual Report ï June 30, 2009

ING Clarion Global Real Estate Income Fund

Statement of Cash Flows ï For the Six Months Ended June 30, 2009 (unaudited)

 

 

See notes to financial statements.

Semi-Annual Report ï June 30, 2009 ï 9

ING Clarion Global Real Estate Income Fund

Financial Highlights ï

 

 

 

See notes to financial statements.

10 ï Semi-Annual Report ï June 30, 2009

ING Clarion Global Real Estate Income Fund

Notes to Financial Statements ï June 30, 2009 (unaudited)

 

 

ING Clarion Global Real Estate Income Fund (the “Trust”) is a non-diversified, closed-end management investment company that was organized as a Delaware statutory trust on November 6, 2003 under the Investment Company Act of 1940, as amended. ING Clarion Real Estate Securities (the “Advisor”) is the Trust’s investment advisor. The Trust commenced operations on February 18, 2004.

 

The following accounting policies are in accordance with U.S. generally accepted accounting principles and are consistently followed by the Trust.

 

Securities Valuation – The net asset value of the common shares of the Trust will be computed based upon the value of the Trust’s portfolio securities and other assets. The Trust calculates net asset value per common share by subtracting the Trust’s liabilities (including accrued expenses, dividends payable and any borrowings of the Trust) and the liquidation value of any outstanding preferred shares from the Trust’s total assets (the value of the securities the Trust holds, plus cash or other assets, including interest accrued but not yet received) and dividing the result by the total number of common shares of the Trust outstanding. Net asset value per common share will be determined as of the close of the regular trading session (usually 4:00 p.m., EST) on the New York Stock Exchange (“NYSE”) on each business day on which the NYSE is open for trading.

 

For purposes of determining the net asset value of the Trust, readily marketable portfolio assets traded principally on an exchange, or on a similar regulated market reporting contemporaneous transaction prices, are valued, except as indicated below, at the last sale price for such assets on such principal markets on the business day on which such value is being determined. If there has been no sale on such day, the securities are valued at the mean of the closing bid and asked prices on such day. Foreign securities are valued based upon quotations from the primary market in which they are traded and are translated from the local currency into U.S. dollars using current exchange rates. Securities and other assets for which market quotations are not readily available or for which the above valuation procedures are deemed not to reflect fair value are valued in a manner that is intended to reflect their fair value as determined in accordance with procedures approved by the Trust’s Board of Trustees (the “Board”).

 

Short-term securities which mature in more than 60 days are valued at current market quotations. Short-term securities, which mature in 60 days or less are valued at, amortized cost, which approximates market value.

 

The Trust adopted Financial Accounting Standards Board Statement of Financial Accounting Standards No. 157, “Fair Value Measurements” (“FAS 157”) effective January 1, 2008. In accordance with FAS 157, fair value is defined as the price that the Trust would receive to sell an investment or pay to transfer a liability in a timely transaction with an independent buyer in the principal market, or in the absence of a principal market the most advantageous market for the investment or liability. FAS 157 establishes a single definition of fair value, creates a three-tier hierarchy as a framework for measuring fair value based on inputs used to value the Trust’s investments, and requires additional disclosure about fair value. The hierarchy of inputs is summarized below:

 

 

For Level 1 inputs, the fund uses unadjusted quoted prices in active markets for assets or liabilities with sufficient frequency and volume to provide pricing information as the most reliable evidence of fair value. The Fund’s Level 2 valuation techniques include inputs other than quoted prices within Level 1 that are observable for an asset or liability, either directly or indirectly. Level 2 observable inputs may include quoted prices for similar assets and liabilities in active markets or quoted prices for identical or similar assets or liabilities in markets that are not active in which there are few transactions, the prices are not current, or price quotations vary substantially over time or among market participants. Inputs that are observable for the asset or liability in Level 2 include such factors as interest rates, yield curves, prepayment speeds, credit risk, and default rates for similar liabilities. For Level 3 valuation techniques, the Fund uses unobservable inputs that reflect assumptions market participants would be expected to use in pricing the asset or liability. Unobservable inputs are used to measure fair value to the extent that observable inputs are not available and are developed based on the best information available under the circumstances. In developing unobservable inputs, market participant assumptions are used if they are reasonably available without undue cost and effort.

 

The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities. The following is a summary of the inputs used for the six months ended June 30, 2009 in valuing the Trust’s investments carried at fair value:

 

Semi-Annual Report ï June 30, 2009 ï 11

ING Clarion Global Real Estate Income Fund ï Notes to Financial Statements continued

 

Foreign Currency Translation – The books and records of the Trust are maintained in U.S. dollars. Foreign currency amounts are translated into U.S. dollars on the following basis:

 

 

 

Although the net assets of the Trust are presented at the foreign exchange rates and market values at the close of each fiscal period, the Trust does not isolate that portion of the results of operations arising as a result of changes in the foreign exchange rates from the fluctuations arising from changes in the market prices of long-term securities held at the end of the fiscal period. Similarly, the Trust does not isolate the effect of changes in foreign exchange rates from the fluctuations arising from changes in the market prices of portfolio securities sold during the fiscal period. Accordingly, realized foreign currency gains or losses will be included in the reported net realized gains or losses on investment transactions.

 

Net realized gains or losses on foreign currency transactions represent net foreign exchange gains or losses from the holding of foreign currencies, currency gains or losses realized between the trade date and settlement date on securities transactions, and the difference between the amounts of dividends, interest and foreign withholding taxes recorded on the Trust’s books and the U.S. dollar equivalent amounts actually received or paid. Net unrealized currency gains or losses from valuing foreign currency denominated assets or liabilities (other than investments) at period end exchange rates are reflected as a component of net unrealized appreciation or depreciation on investments and foreign currencies.

 

Foreign security and currency transactions may involve certain considerations and risks not typically associated with those of domestic origin as a result of, among other factors, the possibility of political or economic instability, or the level of governmental supervision and regulation of foreign securities markets.

 

Forward Exchange Currency Contracts – The Trust may enter into forward exchange currency contracts in order to hedge its exposure to changes in foreign currency exchange rates on its foreign portfolio holdings, to hedge certain firm purchase and sales commitments denominated in foreign currencies and for investment purposes. A forward exchange currency contract is a commitment to purchase or sell a foreign currency on a future date at a negotiated forward rate. The gain or loss arising from the difference between the original contracts and the closing of such contracts would be included in net realized gain or loss on foreign currency transactions.

 

Fluctuations in the value of open forward exchange currency contracts are recorded for financial reporting purposes as unrealized appreciation and depreciation by the Trust.

 

The Trust’s custodian will place and maintain cash not available for investment or other liquid assets in a separate account of the Trust having a value at least equal to the aggregate amount of the Trust’s commitments under forward exchange currency contracts entered into with respect to position hedges.

 

Risks may arise from the potential inability of a counterparty to meet the terms of a contract and from unanticipated movements in the value of a foreign currency relative to the U.S. dollar. The face or contract amount, in U.S. dollars, reflects the total exposure the Trust has in that particular currency contract. As of June 30, 2009, the Trust did not hold any forward exchange currency contracts.

 

Securities Transactions and Investment Income – Securities transactions are recorded on a trade date basis. Realized gains and losses from securities transactions are recorded on the basis of identified cost. Dividend income is recorded on the ex-dividend date. Distributions received from investments in REITs are recorded as dividend income on ex-dividend date, subject to reclassification upon notice of the character of such distributions by the issuer. The portion of dividend attributable to the return of capital is recorded against the cost basis of the security. Withholding taxes on foreign dividends are recorded net of reclaimable amounts, at the time the related income is earned. Non-cash dividends included in dividend income, if any, are recorded at the fair market value of the securities received. Interest income, including accretion of original issue discount, where applicable, and accretion of discount on short-term investments, is recorded on the accrual basis. Realized gains and losses from securities transactions are recorded on the basis of identified cost.

 

Swaps – The Trust may enter into swap agreements. A swap is an agreement to exchange the return generated by one instrument for the return generated by another instrument. The Trust enters into interest rate swap agreements to manage its exposure to interest rate and credit risk. Interest rate swap agreements involve the exchange by the Trust with another party of their respective commitments to pay or receive interest. Dividends and interest on the securities in the swap are included in the value of the exchange. The swaps are valued daily at current market value and any unrealized gain or loss is included in the Statement of Assets and Liabilities. Gain or loss is realized on the periodic reset date or termination date of the swap and is equal to the difference between the Trust’s basis in the swap and the proceeds of the closing transaction, including any fees. During the period that the swap agreement is open, the Trust may be subject to risk from the potential inability of the counterparty to meet the terms of the agreement. The swaps involve elements of both market and credit risk in excess of the amounts reflected on the Statement of Assets and Liabilities. As of June 30, 2009, the Trust did not have any swap agreements outstanding.

 

Dividends and Distributions to Shareholders – Dividends from net investment income, if any, are declared and paid on a monthly basis. Income dividends and capital gain distributions to common shareholders are recorded on the ex-dividend date. To the extent the Trust’s net realized

12 ï Semi-Annual Report ï June 30, 2009

ING Clarion Global Real Estate Income Fund ï Notes to Financial Statements continued

 

capital gains, if any, can be offset by capital loss carryforwards, it is the policy of the Trust not to distribute such gains.

 

On August 5, 2008, the Fund acting in accordance with an exemptive order received from the Securities and Exchange Commission and with approval of its Board of Trustees, adopted a managed distribution policy under which the Fund intends to make regular monthly cash distributions to common shareholders, stated in terms of a fixed amount per common share. With this new policy the Fund can now include long-term capital gains in its distribution as frequently as twelve times a year. In practice, the Board of Trustees views their approval of this policy as a potential means of further supporting the market price of the Fund through the payment of a steady and predictable level of cash distributions to shareholders.

 

The current monthly rate is $0.045 per share. The Trust continues to evaluate its monthly distribution policy in light of ongoing economic and market conditions and may change the amount of the monthly distributions in the future.

 

Use of Estimates – The preparation of financial statements, in conformity with U.S. generally accepted accounting principles, requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities at the date of financial statements and the reported amounts of expenses during the reporting period. Actual results could differ from those estimates.

 

Reclassification – Certain amounts in the financial statements of prior periods have been reclassified to conform with the presentation used in the current period financial statements. These reclassifications have no effect on net income.

 

Under normal market conditions, the Trust’s investments will be concentrated in income-producing common equity securities, preferred securities, convertible securities and non-convertible debt securities issued by companies deriving the majority of their revenue from the ownership, construction, financing, management and/or sale of commercial, industrial, and/or residential real estate. Values of the securities of such companies may fluctuate due to economic, legal, cultural, geopolitical or technological developments affecting various global real estate industries.

 

Pursuant to an investment management agreement between the Advisor and the Trust, the Advisor is responsible for the daily management of the Trust’s portfolio of investments, which includes buying and selling securities for the Trust, as well as investment research. The Trust pays for investment advisory services and facilities through a fee payable monthly in arrears at an annual rate equal to 0.85% of the average weekly value of the Trust’s managed assets (which includes the amount from the issuance of preferred shares) plus certain direct and allocated expenses of the Advisor incurred on the Trust’s behalf. The Advisor has agreed to waive a portion of its management fee in the amount of 0.25% of the average weekly values of the Trust’s managed assets for the first five years of the Trust’s operations (through February, 2009), and for a declining amount for an additional four years (through February, 2013). During the six months ended June 30, 2009, the Trust incurred management fees of $1,963,771, which are net of $692,962 in management fees waived by the Advisor.

 

The Trust has multiple service agreements with The Bank of New York Mellon (“BNYM”) formerly known as The Bank of New York. Under the servicing agreements, BNYM will perform custodial, fund accounting, certain administrative services, and transfer agency services for the Trust. As custodian, BNYM is responsible for the custody of the Trust’s assets. As administrator, BNYM is responsible for maintaining the books and records of the Trust’s securities and cash. As transfer agent, BNYM is responsible for performing transfer agency services for the Trust.

 

For the six months ended June 30, 2009, there were purchases and sales transactions (excluding short-term securities) of $43,678,203 and $324,591,771, respectively.

 

The Trust intends to elect to be, and qualify for treatment as, a regulated investment company under Subchapter M of the Internal Revenue Code of 1986, as amended (the “Code”). A regulated investment company generally pays no federal income tax on the income and gains that it distributes. The Trust intends to meet the calendar year distribution requirements imposed by the Code to avoid the imposition of a 4% excise tax.

 

Effective June 29, 2007, the Fund adopted FASB Interpretation No. 48, “Accounting for Uncertainty in Income Taxes” (“FIN 48”). FIN 48 provides guidance for how uncertain tax positions should be recognized, measured, presented and disclosed in the financial statements. FIN 48 requires the evaluation of tax positions taken or expected to be taken in the course of preparing the Trust’s tax returns to determine whether the tax positions are “more-likely-than-not” of being sustained by the applicable tax authority. Tax positions not deemed to meet the “more-likely-than-not” threshold are recorded as a tax benefit or expense in the current year. The adoption of FIN 48 did not result in the recording of any tax benefit or expense in the current period. As of and during the period ended June 30, 2009, the Fund did not have a liability for any unrecognized tax benefits. The Fund recognizes interest and penalties, if any, related to unrecognized tax benefits as income tax expense in the Statement of Operations. During the period, the Fund did not incur any interest or penalties. Each of the tax years in the three-year period ended December 31, 2008, remains subject to examination by the Internal Revenue Service. Management’s determination regarding FIN 48 may be subject to review and adjustment at a later date based on factors including, but not limited to, an on-going analysis of tax laws, regulations and interpretations thereof.

Semi-Annual Report ï June 30, 2009 ï 13

ING Clarion Global Real Estate Income Fund ï Notes to Financial Statements continued

 

The Trust distinguishes between dividends on a tax basis and on a financial reporting basis and only distributions in excess of tax basis earnings and profits are reported in the financial statements as a tax return of capital. Differences in the recognition or classification of income between the financial statements and tax earnings and profits which result in temporary over-distributions for financial statement purposes are classified as distributions in excess of net investment income or accumulated net realized losses in the components of net assets on the Statement of Assets and Liabilities.

 

In order to present paid-in capital in excess of par and accumulated net realized gains or losses on the Statement of Assets and Liabilities that more closely represent their tax character, certain adjustments have been made to additional paid-in capital, undistributed net investment income and accumulated net realized gains or losses on investments. For the year ended December 31, 2008, the adjustments were to decrease additional paid-in capital by $232,539,932, increase accumulated net realized loss on investments by $16,506,783 and increase undistributed net investment income by $216,033,149 due to the difference in the treatment for book and tax purposes of certain investments. Results of operations and net assets were not affected by these reclassifications.

 

The final determination of the source of the 2009 distributions for tax purposes will be made after the end of the Trust’s fiscal year and will be reported to shareholders in February 2009 on Form 1099-DIV.

 

Information on the components of net assets as of June 30, 2009 is as follows:

 

 

For the year ended December 31, 2008, the tax character of distributions paid, as reflected in the Statements of Changes in Net Assets, was $96,116,265 of long-term capital gain and $58,420,284 of return of capital.

 

The Trust leverages through the issuance of preferred shares, and/or borrowings in an aggregate amount of approximately 35% of the Trust’s capital to buy additional securities. The Trust may borrow from banks or other financial institutions. The use of preferred shares and other borrowing techniques to leverage the common shares can create risks.

 

The Trust has access to a secured line of credit up to $300,000,000 from BNYM for borrowing purposes. Borrowings under this arrangement bear interest at the Federal funds rate plus 75 basis points. At June 30, 2009, there were borrowings in the amount of $22,810,900 on the Trust’s line of credit.

 

The average daily amount of borrowings during the six months ended June 30, 2009 was $14,161,971, with a related weighted average interest rate of 0.94%. The maximum amount outstanding for the six months ended June 30, 2009, was $32,818,700.

 

During 2004, the Trust issued 101,000,000 shares of common stock at $15.00. In connection with the Trust’s DRIP plan, the Trust issued 0 and 1,524,749 common shares in June 30, 2009 and 2008, respectively. At June 30, 2009, the Trust had outstanding common shares of 104,201,527 with a par value of $0.001 per share. The Advisor owned 6,981 shares of the common shares outstanding.

 

At December 31, 2008, the Trust had 14,800 shares of auction rate preferred securities authorized, issued and outstanding.

 

On February 18, 2009, the Trust redeemed 1,624 shares of Preferred Shares Series T28C and 2,528 shares of Preferred Shares Series T7. On February 19, 2009, the Trust redeemed 2,528 of Preferred Shares Series W7. On February 20, 2009, the Trust redeemed 1,624 shares of Preferred Shares Series TH7. On February 23, 2009, the Trust redeemed 1,624 shares of Preferred Shares Series F7. On February 26, 2009, the Trust redeemed 1,624 shares of Preferred Shares Series W28D. On March 4, 2009, the Trust redeemed 1,624 shares of Preferred Shares Series T28A. On March 12, 2009, the Trust redeemed 1,624 shares of Preferred Shares Series W28B.

 

For the period ended March 2009, the annualized dividend rates ranged from:

 

 

Following the completion of the redemptions, 100% of the auction-rate preferred securities will have been redeemed.

 

The Trust enters into contracts that contain a variety of indemnifications. The Trust’s exposure under these arrangements is unknown. However, the Trust has not had prior claims or losses or current claims or losses pursuant to these contracts.

 

On April 2009, FASB issued Staff Position No. 157-4, Determining Fair Value When the Volume and Level of Activity for the Asset or Liability Have Significantly Decreased and Identifying Transactions That Are Not Orderly (“FSP 157-4”). FSP 157-4 provides additional guidance for estimating fair value in accordance with FAS 157 when the volume and level of activity for the asset or liability have significantly decreased. FSP 157-4 also requires additional disaggregation of the current FAS 157 required disclosures.

14 ï Semi-Annual Report ï June 30, 2009

ING Clarion Global Real Estate Income Fund ï Notes to Financial Statements continued

 

FSP 157-4 is effective for interim and annual reporting periods ending after June 15, 2009.

 

At a meeting on February 5, 2009, the Board of Trustees approved the merger of the Trust with the ING Clarion Real Estate Income Fund (IIA) (the “Reorganization”), subject to the satisfaction of applicable regulatory requirements and the conditions precedent set forth in the Agreement and Plan of Reorganization between the Trust and IIA (including without limitation the receipt by the Trust of an opinion of counsel to the effect that the Reorganization meets the requirements of a tax-free reorganization under the Internal Revenue Code). The Reorganization requires the approval of a majority of IIA’s outstanding shares, but does not require the approval of the Trust’s shareholders. Although the Board of Trustees has approved it, the Reorganization may not occur if the shareholders of IIA do not approve it or if another condition precedent is not met. As of August 21, 2009, the shareholders of IIA have approved the reorganization.

 

In accordance with the provisions of Statement of Financial Accounting Standards No. 165 Subsequent Event, management of the fund has evaluated the possibility of subsequent events existing in the Fund’s financial statements through August 28, 2009. Management has determined that there are no material events that would require disclosure in the Fund’s financial statements through this date.

Semi-Annual Report ï June 30, 2009 ï 15

ING Clarion Global Real Estate Income Fund

Supplemental Information ï (unaudited)

 

Trustees

 

The Trustees of the ING Clarion Global Real Estate Income Fund and their principal occupations during the past five years:

 

16 ï Semi-Annual Report ï June 30, 2009

ING Clarion Global Real Estate Income Fund ï Supplemental Information continued

 

 

 

Officers

The Officers of the ING Clarion Global Real Estate Income Fund and their principal occupations during the past five years:

 

 

Additional Information

 

Statement of Additional Information includes additional information regarding the Trustees. This information is available upon request, without charge, by calling the following toll-free telephone number: 1-888-711-4272.

 

The Trust has delegated the voting of the Trust’s voting securities to the Trust’s advisor pursuant to the proxy voting policies and procedures of the advisor. You may obtain a copy of these policies and procedures by calling 1-888-711-4272. The policies may also be found on the website of the Securities and Exchange Commission (http://www.sec.gov).

 

Information regarding how the Trust voted proxies for portfolio securities, if applicable, during the most recent 12-month period ended June 30, is also available, without charge and upon request by calling the Trust at 1-888-711-4272 or by accessing the Trust’s Form N-PX on the Commission’s website at http://www.sec.gov.

 

The Trust files its complete schedule of portfolio holdings with the Securities and Exchange Commission for the first and third quarters of each fiscal year on Form N-Q. The Trust’s Form N-Qs are available on the SEC website at http://www.sec.gov. The Trust’s Form N-Qs may also be viewed and copied at the Commission’s Public Reference Room in Washington, DC; information on the operation of the Public Reference Room may be obtained by calling (800) SEC-0330.

Semi-Annual Report ï June 30, 2009 ï 17

ING Clarion Global Real Estate Income Fund ï Supplemental Information continued

 

Board Considerations in Approving the Advisory Agreement

On May 18, 2009, the Board approved the continuation of the investment management agreement (the “Advisory Agreement”) between the Advisor and the Trust. Overall, the Board concluded that continuation of the Advisory Agreement was in the best interests of the Trust and consistent with shareholder expectations. During the course of its deliberations, the Board was informed with respect to publicly available information relating to other closed-end investment companies whose investment objectives and policies are similar to the Trust, as well as information relating to other accounts managed by the Advisor whose investment objectives and policies are similar to the Trust. In determining to approve the Advisory Agreement, the Board took into account a number of factors, without assigning relative weight to any factor or identifying any factor as determinative. Rather, the Board based its finding on the specific facts and circumstances of the Trust.

 

In approving the continuation of the Advisory Agreement, the Board reviewed the nature, extent and quality of advisory services provided by the Advisor, including the performance achieved by the Advisor for the Trust in difficult market conditions, the consistency of the Advisor’s investment decision process, the experience of the Advisor’s personnel and the administrative resources devoted by the Advisor to oversight of the Trust’s operations. The Board concluded, particularly in light of the Trust’s strategic focus on providing income to its shareholders and current economic trends and conditions, that both the Trust’s relative performance and administrative and related compliance oversight procedures were satisfactory and supported renewal of the Advisory Agreement.

 

The Board also considered the level of compensation and other benefits received by the Advisor as a result of its relationship with the Trust. Based on this review, the Board concluded that the advisory fee to which the Advisor is entitled under the Advisory Agreement is not excessive, viewed in light of the quality of the services provided by the Advisor, fees charged to other managed accounts, as well as fees and expenses paid by closed-end investment companies in the Trust’s peer group. During the course of its review, the Board also considered information relating to the costs incurred by the Advisor in connection with the provision of services to the Trust, the services provided to the Trust that are not provided to other clients and how those services account for the range of fees charged by the Advisor to the Trust and its other clients. The Trustees also considered the potential that the Advisor may realize “fall out benefits” as a result of its relationship with the Trust, as well as the fee waiver afforded to the Trust by the Advisor. The Board concluded that, based on the profit levels reported by the Advisor and in light of the specific circumstances of the Trust (including allowance for the continued ability of the Advisor to attract and retain talented employees), the advisory fee paid to the Advisor in accordance with the Advisory Agreement has not resulted in profits that are excessive or beyond the range that would have been negotiated at arm’s length. The Board did not specifically consider the potential for realization of economies of scale because the Trust is a closed-end vehicle with limited potential for asset growth.

18 ï Semi-Annual Report ï June 30, 2009

ING Clarion Global Real Estate Income Fund

Dividend Reinvestment Plan ï (unaudited)

 

 

Pursuant to the Trust’s Dividend Reinvestment Plan (the “Plan”), shareholders of the Trust are automatically enrolled, to have all distributions of dividends and capital gains reinvested by The Bank of New York Mellon (the “Plan Agent”) in the Trust’s shares pursuant to the Plan. You may elect not to participate in the Plan and to receive all dividends in cash by sending written instructions or by contacting The Bank of New York Mellon, as dividend disbursing agent, at the address set forth below. Participation in the Plan is completely voluntary and may be terminated or resumed at any time without penalty by contacting the Plan Agent before the dividend record date; otherwise such termination or resumption will be effective with respect to any subsequently declared dividend or other distribution. Shareholders who do not participate in the Plan will receive all distributions in cash paid by check and mailed directly to the shareholders of record (or if the shares are held in street or other nominee name, then to the nominee) by the Plan Agent, which serves as agent for the shareholders in administering the Plan.

 

After the Trust declares a dividend or determines to make a capital gain distribution, the Plan Agent will acquire shares for the participants’ account, depending upon the circumstances described below, either (i) through receipt of unissued but authorized shares from the Trust (“newly issued shares”) or (ii) by open market purchases. If, on the dividend payment date, the NAV is equal to or less than the market price per share plus estimated brokerage commissions (such condition being referred to herein as “market premium”), the Plan Agent will invest the dividend amount in newly issued shares on behalf of the participants. The number of newly issued shares to be credited to each participant’s account will be determined by dividing the dollar amount of the dividend by the NAV on the date the shares are issued. However, if the NAV is less than 95% of the market price on the payment date, the dollar amount of the dividend will be divided by 95% of the market price on the payment date. If, on the dividend payment date, the NAV is greater than the market value per share plus estimated brokerage commissions (such condition being referred to herein as “market discount”), the Plan Agent will invest the dividend amount in shares acquired on behalf of the participants in open-market purchases.

 

The Plan Agent’s fees for the handling of the reinvestment of dividends and distributions will be paid by the Trust. However, each participant will pay a pro rata share of brokerage commissions incurred with respect to the Plan Agent’s open market purchases in connection with the reinvestment of dividends and distributions. The automatic reinvestment of dividends and distributions will not relieve participants of any Federal income tax that may be payable on such dividends or distributions.

 

The Trust reserves the right to amend or terminate the Plan. There is no direct service charge to participants in the Plan; however, the Trust reserves the right to amend the Plan to include a service charge payable by the participants. Participants that request a sale of shares through the Plan Agent are subject to a $2.50 sales fee and a $0.15 per share sold brokerage commission. All correspondence concerning the Plan should be directed to the Plan Agent at BNY Mellon Shareowner Services, P.O. Box 358015, Pittsburgh, PA 15252-8015, Phone Number: (866) 221-1580.

Semi-Annual Report ï June 30, 2009 ï 19

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20 ï Semi-Annual Report ï June 30, 2009

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Semi-Annual Report ï June 30, 2009 ï 21

ING Clarion Global Real Estate Income Fund

           Fund Information ï

 

Board of Trustees

T. Ritson Ferguson

Jarrett B. Kling

Asuka Nakahara

Frederick S. Hammer

Richard L. Sutton

John Bartholdson

 

Officers

T. Ritson Ferguson

President and

Chief Executive Officer

 

Jonathan A. Blome

Chief Financial Officer

 

William E. Zitelli

Chief Compliance Officer and

Secretary

 

Investment Advisor

ING Clarion Real Estate Securities

201 King of Prussia Road

Radnor, PA 19087

888-711-4272

www.ingclarionres.com

 

Administrator, Custodian and Transfer Agent

The Bank of New York Mellon

New York, New York

 

Preferred Shares – Dividend Paying Agent

The Bank of New York Mellon

New York, New York

 

Legal Counsel

Morgan, Lewis & Bockius, LLP

Washington, DC

 

Independent Registered Public Accounting Firm

Ernst & Young LLP

Philadelphia, Pennsylvania

Item 2. Code of Ethics.

Not applicable for semi-annual reporting period.

Item 3. Audit Committee Financial Expert.

Not applicable for semi-annual reporting period.

Item 4. Principal Accountant Fees and Services.

Not applicable for semi-annual reporting period.

Item 5. Audit Committee of Listed Registrants.

Not applicable for semi-annual reporting period.

Item 6. Investments.

The schedule of investments is included as part of the report to shareholders filed under Item 1 of this form.

Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.

Not applicable for semi-annual reporting period.

Item 8. Portfolio Managers of Closed-End Management Investment Companies.

Not applicable for semi-annual reporting period.

Item 9. Purchases of Equity Securities by Closed-End Management Investment Company and Affiliated Purchasers.

None.

Item 10. Submission of Matters to a Vote of Security Holders.

Not applicable.

Item 11. Controls and Procedures.

(a) The Trust’s principal executive officer and principal financial officer have evaluated the Trust’s disclosure controls and procedures within 90 days of this filing and have concluded that the Trust’s disclosure controls and procedures were effective, as of that date, in ensuring that information required to be disclosed by the Trust in this Form N-CSR was recorded, processed, summarized, and reported timely.

(b) The Trust’s principal executive officer and principal financial officer are aware of no changes in the Trust’s internal control over financial reporting that occurred during the Trust’s second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Trust’s internal control over financial reporting.

Item 12. Exhibits.

(a)(1) Not applicable.

(a)(2) Certification of chief executive officer and chief financial officer pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

(b) Certification of chief executive officer and chief financial officer pursuant to Section 906 of the Sarbanes-Oxley Act of 2002.

SIGNATURES

     Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

(Registrant) ING Clarion Global Real Estate Income Fund

By:		/s/ T. Ritson Ferguson
Name:		T. Ritson Ferguson
Title:		President and Chief Executive Officer
Date:		October 2, 2009

     Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By:		/s/ T. Ritson Ferguson
Name:		T. Ritson Ferguson
Title:		President and Chief Executive Officer
Date:		October 2, 2009

By:		/s/ Jonathan A. Blome
Name:		Jonathan A. Blome
Title:		Chief Financial Officer
Date:		October 2, 2009