April 30, 2019

J. Kevin Willis
Chief Financial Officer
Ashland Global Holdings Inc.
50 E. RiverCenter Boulevard
Covington, Kentucky 41011

       Re: Ashland Global Holdings Inc.
           Form 10-K for the year ended September 30, 2018
           Filed November 19, 2018
           File No. 333-211719

Dear Mr. Willis:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. We may ask you to provide us with
information so
we may better understand your disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K for the year ended September 30, 2018

Note M - Income Taxes, page F-35

1.    Please reconcile the disclosures surrounding the impact of the Tax Act
you provided on
      page F-35 with the information you have presented in your reconciliation
of the statutory
      federal income tax to your provision for income taxes on page F-37.
Ensure that the tax
      reform amounts presented in the reconciliation and related footnotes are
transparent such
      that a reader understands the impact the Tax Act had on your provision
for income taxes.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Jenn Do at (202) 551-3743 or Jeanne Baker at (202)
551-3691 with any
questions.
 J. Kevin Willis
Ashland Global Holdings Inc.
April 30, 2019
Page 2



                                            Sincerely,
FirstName LastNameJ. Kevin Willis
                                            Division of Corporation Finance
Comapany NameAshland Global Holdings Inc.
                                            Office of Manufacturing and
April 30, 2019 Page 2                       Construction
FirstName LastName