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CORRESP
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CORRESP

 Brookfield Real Estate Income Trust Inc.

250 Vesey Street, 15th Floor

 New
York, NY 10281

 August 29, 2023

 VIA
EDGAR

 United States Securities and Exchange Commission

Division of Corporation Finance

 Office of Real Estate &
Construction

 Washington, DC 20549

Re:
 Brookfield Real Estate Income Trust, Inc.

Form 10-K for the year ended December 31, 2022

Filed March 16, 2023

 Form 10-Q for the quarterly period ended March 31, 2023

 Filed May 12, 2023

File No. 000-56428

Dear Sir or Madam:

 This letter sets forth the
response of Brookfield Real Estate Income Trust Inc. (the “Company”) to the correspondence from the Securities and Exchange Commission (“SEC”) dated August 4, 2023 regarding the Company’s Form 10-K for the year
ended December 31, 2022, which was filed with the SEC on March 16, 2023, and the Company’s Form 10-Q for the quarterly period ended March 31, 2023, which was filed with the SEC on May 12, 2023. The
SEC’s comments are below, followed by the Company’s responses thereto.

 Comment:

Form 10-K for the year ended December 31, 2022

Item 5. Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer

Purchases of Equity Securities

 Net Asset Value, page
49

1.
 We note your response to comment 1. Please provide us with a quantitative detail or reconciliation of how you
derived the amount of net asset value (“NAV”) allocated to each class of share. This quantitative information should be based on the multiple factors listed in your response (e.g. class-specific adjustments for repurchases of the
Company’s common stock effective on the last calendar day of that month and accruals of class-specific expenses). In your response, please supplement your quantitative information with sufficient narrative disclosure to clearly explain how each
component is derived. Additionally, please tell us what consideration you gave to enhancing your NAV disclosures in your filing to provide this quantitative information to enable investors to better understand how you allocated NAV to each class of
share.

 Response:

In response to the request by the staff, the Company provides the table attached in Exhibit A to this letter with a quantitative
reconciliation of the allocation of NAV to each share class on a monthly basis. The table reflects each component of the change in NAV by share class and the footnotes contain a detailed narrative that explains how each component is derived. For
purposes of this response, the Company shows the allocation by share class for the month of July 2023.

 The Company will revise its
disclosure in its Form 10-K for the year ended December 31, 2023, to provide a detailed narrative explaining how each component of the change in NAV is derived by share class by incorporating the edits to
the disclosure from its Form 10-K for the year ended December 31, 2022, attached in Exhibit B to this letter.

The Company has considered including the disclosure attached in Exhibit A in its future Form
10-K filings and does not intend to add such disclosure for the following reasons:

a)
 The calculation methodology in Exhibit A is sufficiently detailed in the Company’s existing
disclosures in its Form 10-K, as supplemented with the additional disclosure set forth in Exhibit B.

b)
 The NAV disclosures the Company believes are most meaningful are already provided in the Company’s Form 10-K and Form 10-Q filings. The Company believes the most meaningful information for stockholders is (i) the components of NAV on an aggregate basis, which includes the
fair values of the Company’s assets and liabilities, and (ii) the disclosure of the key assumptions that are used to determine the values of the Company’s property investments.

c)
 NAV appreciation is allocated proportionally to each share class on a monthly basis based on the NAV of each
share class as a percentage of the Company’s aggregate NAV. As a result, each stockholder receives the same pro-rata allocation of net appreciation, regardless of the class of shares. The only components
of NAV that are not allocated proportionally are class-specific expenses, which are deducted from the Company’s gross distribution, and the differences in the fees charged to each share class are adequately explained in the Company’s
existing disclosures.

 Comment:

Form 10-Q for the quarterly period ended March 31, 2023

Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of Operations, page 36

2.
 We note your response to comment 3. Please revise future filings to separately quantify the material components
identified as contributing to the change in revenues between periods. This comment is also applicable to any income statement line item that is impacted by multiple factors.

 2

 Response:

The Company will quantify the material components that contribute to changes in revenue between periods as well as changes to any other income
statement line item that is impacted by multiple factors.

 Please contact me if you should need additional information or should you have
questions.

 Sincerely,

 Brookfield Real Estate Income Trust Inc.

By:

/s/ Dana Petitto

 Dana Petitto

 Chief Financial Officer

cc:
 Jason W. Goode, Alston & Bird LLP

Michelle L. Campbell, Brookfield Real Estate Income Trust Inc.

 3

 Exhibit A

 ($ and shares/units in thousands, except per
share/unit
data)

Class S
Shares

Class I
Shares

Class D
Shares

Class T
Shares(1)

Class C
Shares(1)

Class E
Shares(1)

Third-party
Operating
Partnership
Units(2)

Total

 NAV as of June 30, 2023

$
453,813

$
531,682

$
1,648

$
—

$
121,073

$
42,343

$
961

$
1,151,520

 Subscriptions(3)

2,937

3,939

172

—

—

—

—

7,048

 Distribution Reinvestment(4)

1,014

1,886

—

—

—

210

6

3,116

 NAV for allocation

$
457,764

$
537,507

$
1,820

$
—

$
121,073

$
42,553

$
967

$
1,161,684

 Allocation %

39
%

46
%

< 1
%

—%

10
%

4
%

<1
%

 Allocation of NAV Appreciation(5)

$
649

$
764

$
3

$
—

$
172

$
60

$
2

$
1,650

 Other Changes in NAV and Class-Specific Expenses

 Distributions(6)

(1,869
)

(2,557
)

(8
)

—

(593
)

(247
)

(6
)

(5,280
)

 Management Fee(7)

(463
)

(555
)

(2
)

—

(126
)

—

—

(1,146
)

 Stockholder Servicing Fee(8)

(330
)

—

(1
)

—

—

—

—

(331
)

 Performance Fee(9)

—

—

—

—

—

—

—

—

 Repurchases(10)

(13,989
)

(5,326
)

—

—

—

—

—

(19,315
)

 NAV as of July 31, 2023

$
441,762

$
529,833

$
1,812

$
—

$
120,526

$
42,366

$
963

$
1,137,262

 Number of shares/units outstanding

35,580

42,366

144

—

9,856

3,395

77

91,418

 NAV Per Share/Unit as of July 31, 2023

$
12.4159

$
12.5063

$
12.5746

$
—

$
12.2284

$
12.4806

$
12.4806

(1)
 No Class T shares have been sold. Class C and Class E shares of the Company’s common stock
are sold pursuant to private offerings.

(2)
 Includes the units of the Operating Partnership held by parties other than the Company.

(3)
 Represents subscription proceeds received for shares issued on the first calendar day of the month, net of
upfront selling commissions which are recorded as offering costs under GAAP.

(4)
 Distributions reinvested by stockholders pursuant to the Company’s Distribution Reinvestment Plan.

(5)
 Includes net portfolio income from investments, interest expense, realized and unrealized net real estate
appreciation, general and administrative expenses, and reimbursements paid to the Adviser for previously advanced organization and offering costs. Unrealized net real estate appreciation includes any changes in the fair market value of the
Company’s investments in real estate, investments in real estate-related loans, and debt liabilities, which are presented at their carrying value in the Company’s GAAP consolidated financial statements. Allocation of NAV Appreciation
excludes straight-line rental revenue, depreciation and amortization, which are recognized as components of net income under GAAP. Allocated amounts may not recalculate due to rounding.

(6)
 Net distributions declared during the month. The net distribution per share will differ by share class due to
the allocation of class-specific expenses, including stockholder servicing fees, management fees and performance fees.

(7)
 Management fees are a class-specific expense and payable monthly on Class C, Class D, Class I,
Class S and Class T shares of common stock. The Company accrues a monthly management fee equal to 1/12 of 1.25% of the NAV of the Company’s Class C, Class D, Class I, Class S and Class T common shares on the
last day of the month, prior to giving effect to distributions, accrued stockholder servicing fees, and accrued performance fees.

(8)
 Stockholder servicing fees are a class-specific expense and payable monthly on Class T, Class S, and
Class D common shares. For purposes of calculating NAV, the stockholder servicing fee is recognized as reduction of NAV on a monthly basis as such fee becomes payable. Under GAAP, the Company accrues the full cost of the stockholder servicing
fee payable over the life of each share (assuming such share remains outstanding the length of time required to pay the maximum stockholder servicing fee) as an offering cost at the time such share is sold. The stockholder servicing fee is
calculated as a percentage of the aggregate NAV for such class of shares.

(9)
 Performance fees are a class-specific expense and accrued monthly based on the total return of the
Company’s Class C, Class D, Class I, Class S and Class T common shares. Total return is defined as distributions paid or accrued plus the change in NAV of the Company’s Class C, Class D, Class I,
Class S and Class T common shares, adjusted for subscriptions and repurchases.

(10)
 Repurchases of common stock effective on the last calendar day of the month.

 4

 Exhibit B

Net Asset Value

 Our board of directors, including a
majority of our independent directors, has adopted valuation guidelines that contain a comprehensive set of methodologies to be used by the Adviser and our independent valuation advisor in connection with estimating the values of our assets and
liabilities for purposes of our NAV calculation. The calculation of our NAV is intended to be a calculation of the fair value of our assets less our outstanding liabilities as described below and will likely differ from the book value of our equity
reflected in our financial statements. As a public company, we are required to issue financial statements based on historical cost in accordance with GAAP, which are subject to an annual independent audit.

To calculate our NAV for the purpose of establishing a purchase and repurchase price for our shares, we have adopted a model that adjusts the value of our
assets and liabilities from historical cost to fair value generally in accordance with the GAAP principles set forth in Financial Accounting Standards Board (FASB) Accounting Standards Codification Topic 820, Fair Value Measurements and Disclosures.
However, our valuation procedures and our NAV are not subject to independent audit. Because the fair value calculations of our real estate properties involve significant professional judgment in the application of both observable and unobservable
inputs, the calculated fair value of our assets may differ from their actual realizable value or future fair value. While we believe our NAV calculation methodologies are consistent with standard industry practices, there is no rule or regulation
that requires us to calculate NAV in a certain way. As a result, other public REITs may use different methodologies or assumptions to determine NAV. In addition, NAV is not a measure used under GAAP and the valuations of and certain adjustments made
to our assets and liabilities used in the determination of NAV will differ from GAAP.

 With the approval of our board of directors, including a majority
of the independent directors, we have engaged Altus Group U.S. Inc. to serve as our independent valuation advisor. At the end of each month, our independent valuation advisor prepares appraisals for each of our properties other than those for which
we obtained third-party annual appraisals for such month, and reviews annual appraisals for each of our properties for which an appraisal was obtained from an independent third-party appraisal firm. While our independent valuation advisor performs
an important role with respect to our property valuations, our independent valuation advisor is not responsible for, and does not calculate, our NAV. The Adviser is ultimately responsible for the determination of our NAV.

The following valuation methods are used for purposes of calculating our NAV:

•

 Investments in Real Estate: Our independent valuation advisor and independent third-party appraisal firms
value our properties using the discounted cash flow methodology (income approach) as the primary methodology, whereby a property’s value is calculated by discounting the estimated cash flows and the anticipated terminal value of the subject
property by the assumed market supported discount and terminal capitalization rate. Consistent with industry practices, the income approach also incorporates subjective judgments regarding comparable rental and operating expense data, capitalization
and discount rates, and projections of future rent and expenses based on appropriate market evidence as well as the residual value of the asset as components in determining value. The valuations of our properties also incorporate historical
operating revenues and expenses of the properties, lease agreements on the properties, budgeted revenues and expenses of the properties, information regarding recent or planned capital expenditures and any other information relevant to valuing the
real estate property.

 5

 For the purposes of calculating our monthly NAV, our properties initially will be valued at
cost, which we expect to represent fair value at that time. Each property, other than single-family rental properties, will then be appraised by an independent third-party appraisal firm after acquisition and no less than annually thereafter. Each
month thereafter our independent valuation advisor will prepare an update appraisal of our properties that are not being appraised by an independent third-party appraisal firm. Our single-family rental properties are valued by our independent
valuation advisor each month. Our non-U.S. property is generally valued in accordance with the same valuation methods, but is valued by an independent third-party appraisal firm every month.

•

 Investments in Real Estate-Related Loans and Securities: Our real estate-related securities are valued
monthly using market quotations from third-party pricing vendors, and our real estate-related debt investments are valued monthly using valuations prepared by independent third-party valuation providers. Market quotations may be obtained from
third-party pricing service providers or broker-dealers. If market quotations are not readily available (or are otherwise not a reliable indication of fair value for a particular investment), the fair value will be determined in good faith by the Sub-Adviser.

 Certain real estate-related debt investments, such as private real estate
loans, are unlikely to have market quotations. Such investments are valued monthly by a third-party valuation provider using generally accepted valuation methodologies to value such investments. Generally, the third-party valuation provider’s
analysis will consider the underlying collateral real estate, the investment’s yield, and the current market yield. Market yield is estimated based on a variety of inputs regarding the collateral asset’s performance, local/macro real
estate performance, and capital market conditions.

•

 Liabilities: We include the fair value of our liabilities as part of our NAV calculation. These
liabilities include the fees payable to the Adviser (including any accrue