SecProbe.io

CORRESP
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filename1.htm

November 2, 2022

VIA
EDGAR

Mr.
William Demarest

Staff
Accountant

Office
of Real Estate and Construction

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, NE

Washington,
DC 20549

    Re:
     Ares Real Estate Income Trust Inc. (the “Company”)

    Form 10-K for the year ended December 31, 2021

    Filed March 14, 2022

    File No. 000-52596

Dear
Mr. Demarest:

We
are writing in response to the comment letter from the Staff of the Commission’s Division of Corporation Finance, dated October
14, 2022, regarding the Company’s Form 10-K for the year ended December 31, 2021. For your convenience, we have reproduced below
the comment from the comment letter and included the Company’s response.

Form
10-K for the Fiscal Year Ended December 31, 2021

Additional
Measures of Performance

Net
Income and NOI, page 75

1. We
                                            note that your disclosure under this heading references the reconciliation on page 72, which
                                            appears to be in the form of a full non-GAAP income statement. In future periodic filings,
                                            to avoid a non-GAAP prominence issue, please include a reconciliation that begins with the
                                            most directly comparable GAAP measure, which appears to be Net income, and reconciles down
                                            to NOI. Refer to Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure
                                            Interpretations.

Response:
A revised version of the reconciliation referenced is shown on the next page. This reconciliation begins with net income. The Company
will present the reconciliation in this manner in its future periodic filings.

Mr. William Demarest

November 2, 2022

Page Two

    For the Year Ended

    December 31,

    (in thousands)
    2021
    2020

    Net income (loss) attributable to common stockholders
    $ 30,754
    $ (14,914 )

    Debt-related income
      (9,174 )
      (2,347 )

    Real estate-related depreciation and amortization
      74,415
      62,923

    General and administrative expenses
      8,797
      7,548

    Advisory fees, related party
      21,433
      17,211

    Performance participation allocation
      15,327
      4,608

    Acquisition costs and reimbursements
      2,636
      1,108

    Litigation expense
      —
      2,500

    Impairment of real estate property
      758
      —

    Equity in income from unconsolidated joint venture partnerships
      (114 )
      —

    Other income
      (1,852 )
      (1,037 )

    Interest expense
      70,494
      58,747

    Gain on sale of real estate property
      (77,857 )
      (13,335 )

    Net income (loss) attributable to redeemable noncontrolling interests
      221
      (54 )

    Net income (loss) attributable to noncontrolling interests
      3,565
      (1,091 )

    Net operating income
    $ 139,403
    $ 121,867

    Less: Non-same store NOI
      35,846
      21,884

    Same store NOI
    $ 103,557
    $ 99,983

The
Company acknowledges that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in the filings; (ii) staff
comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to
the filing; and (iii) the Company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If
you need any additional information, or if we can be of any further assistance, please call me at (303) 597-0432.

Sincerely,

/s/ Lainie P. Minnick

Lainie P. Minnick

Managing Director, Chief Financial Officer and Treasurer

    cc:
    Christopher
    R. Stambaugh, Esq.

    DLA
    Piper LLP (US)