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January 15, 2021
R. Scott Dennis
Chief Executive Officer
Invesco Real Estate Income Trust Inc.
1555 Peachtree Street, N.E. Suite 1800
Atlanta, Georgia 30309
Re:Invesco Real Estate Income Trust Inc.
Amendment No. 2 to Draft Registration Statement on Form S-11
Submitted November 12, 2020
Response Dated December 18, 2020
CIK No. 0001756761
Dear Mr. Dennis:
            We have reviewed your December 18, 2020 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment to Draft Registration Statement on Form S-11
Investment Portfolio
Medical Office Portfolio, page 110
1.We note your response letter dated December 18, 2020.   For any completed or probable
acquisition, please provide us with the following information:
•Name or description of the property or investment;
•Actual or expected date of the acquisition or investment;
•Total purchase price or amount invested, inclusive of any debt assumed or entered
into to purchase the property or investment;
•If applicable, your share of the purchase price or amount invested, inclusive of any

 FirstName LastNameR. Scott Dennis
 Comapany NameInvesco Real Estate Income Trust Inc.
 January 15, 2021 Page 2
 FirstName LastName
R. Scott Dennis
Invesco Real Estate Income Trust Inc.
January 15, 2021
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debt assumed or entered into to purchase the property or investment;
•Registrant’s assets as of the date of the acquisition plus the proceeds (net of
commissions) in good faith expected to be raised in the registered offering over the
next 12 months;
•Total cost of the properties acquired immediately prior to filing an initial registration
statement, properties to be acquired upon closing the IPO, and properties identified as
probable future acquisitions; and
•Total assets as of the end of the most recently completed fiscal year required to be
filed at or prior to the date of acquisition.
2.We note your response letter dated December 18, 2020.  Not including any of the
completed or probable acquisitions or investments listed in your response to the above
comment, please tell us if there are any expectations to make additional investments or
purchase additional properties before effectiveness.  To the extent there are additional
investments or properties, please provide us with details about these investments and
properties.
            You may contact Jorge Bonilla at 202-551-3414 or Jennifer Monick at 202-551-3295
if you have questions regarding comments on the financial statements and related matters.
Please contact Ronald (Ron) E. Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Aaron C. Hendricson