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CORRESP
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    Monica
    J. Shilling, P.C.

    To Call
    Writer Directly:

    +1 310 552 4355

    monica.shilling@kirkland.com

    2049
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    Los Angeles, CA 90067

    United States

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    552 4200

    www.kirkland.com

    Facsimile:

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December 2, 2022

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-3628

    Attention:
    Ms. Kimberly A. Browning
 Mr. Michael Spratt

    Re:
    Ares Strategic Income Fund
 Registration Statement on Form N-2
 File Nos. 333-264145 and 814-01512

Ladies and Gentlemen:

This letter is sent on behalf
of Ares Strategic Income Fund (the “Fund”) in response to the comments of the Staff (the “Staff”)
of the United States Securities and Exchange Commission (the “SEC” or “Commission”) communicated
via teleconference to the undersigned on September 2, 2022 and November 21, 2022 (the “Comment Letter”) regarding
Pre-Effective Amendment No. 1 to the Fund’s Registration Statement on Form N-2.

Please note that the Fund
today filed with the Commission Pre-Effective Amendment No. 2 to the Registration Statement (the “Registration Statement”)
reflecting, among other things, the revisions set forth below.

For convenience, we have set
forth below, in italics, the text of the Staff’s comment prior to each of the Fund’s responses. Capitalized terms used but
not defined herein have the meanings set forth in the Registration Statement. We acknowledge that the Fund 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. Please
note that revisions with respect to one portion of the Registration Statement are applicable to all similar portions of the Registration
Statement.

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    Securities and Exchange Commission

    December 2,
    2022

    Page 2

 1. Comment: It has been proposed that the first sentence of the first paragraph on the cover
page be revised to state: “Ares Strategic Income Fund is a newly organized Delaware statutory trust that seeks to invest primarily
in directly originated assets, including debt securities, made to or issued by U.S. middle-market companies, which we generally define
as companies with annual net income before net interest expense, income tax expense, depreciation and amortization (“EBITDA”)
between $10 million and $250 million or more.” Please clarify what is meant by “or more.” The Staff believes
this language is ambiguous as to the size of companies the Fund may invest in.

Response:
The Fund has revised the disclosure on the cover page and throughout the Registration Statement to remove “or more.”

 2. Comment: It has been proposed that the first sentence of the second paragraph on the
cover page be revised to state: “We are a specialty finance company that is a closed-end management investment company organized
as a Delaware statutory trust.” Please define “specialty finance company” in plain English in accordance with the instructions
to Form N-2.

Response:
The Fund has revised the disclosure on the cover page and throughout the Registration Statement to remove “specialty finance
company” from its disclosures.

 3. Comment: The Staff notes that the Fund proposes to delete the disclosure stating that
the Fund is non-diversified. Please explain to the Staff why this disclosure is being deleted and confirm that disclosure as to the Fund’s
investment strategy and corresponding risk factors is consistent with this revision.

Response:
Based on the anticipated holdings of the Fund, the Fund does not intend to be a “non-diversified company” as defined in Section 5(b)(2) of
the 1940 Act. The Fund confirms that the Fund’s investment strategy and corresponding risk factors are consistent with this revision.

 4. Comment: The Staff notes that the Fund proposes to delete “portfolio companies”
in the following bullet point: “the war in Ukraine and Russia and the potential for volatility in energy and other commodity prices
and their impact on the portfolio companies and industries in which we invest.” Please confirm that conforming revisions have been
made throughout the registration statement. Please also conform the usage of “the portfolio companies” and “our portfolio
companies” throughout the Registration Statement.

Response:
The Fund has revised this disclosure throughout the Registration Statement.

 5. Comment: The last paragraph under the first question on page 6 states: “The
Fund, together with the other entities relying on the Co-Investment Exemptive Order, has applied for an amendment to such order to amend
the term, “Follow-On Investment,” consistent with the temporary relief granted by the SEC on April 8, 2020.” Please
clarify this disclosure to note that if the order amending the term “Follow-On Investment” is granted, the amendment would
permit follow-on investments by affiliated investment funds.

Response:
The Fund advises the Staff that the application for amendment to the Co-Investment Exemptive Order was noticed by the Commission on
September 8, 2022 and issued on September 30, 2022. The Fund has revised this disclosure throughout the Registration Statement accordingly.

    Securities and Exchange Commission

    December 2,
    2022

    Page 3

 6. Comment: Your response, in a letter dated August 8, 2022, to Staff Comment #5 on
the initial Registration Statement (the “August Response Letter”) stated that the “Fund does not currently intend
to waive the management fee for the first six months following the date the Fund breaks escrow.” Please confirm that the Adviser,
rather than the Fund, does not currently intend to waive the management fee for the first six months following the date the Fund breaks
escrow or satisfies the minimum offering condition, as applicable.

Response:
The Fund confirms that that the Adviser does not currently intend to waive the management fee for the first six months
following the date the Fund breaks escrow or satisfies the minimum offering condition, as applicable.

 7. Comment: Please confirm whether the newly added “Calculation of Registration Fee”
table should only include Class I Common Shares if the Fund’s Multi-Class Order is not issued before Class S and
Class D Common Shares are offered.

Response:
Pursuant to Item 25.2.s of Form N-2, the Fund will register a certain number of its Common Shares, and not specific classes of
Common Shares. The Fund confirms that it will not offer Class S and Class D Common Shares to shareholders until the Fund
receives its Multi-Class Order. The Fund  has added disclosure on page vi of the Registration Statement to
that effect.

 8. Comment: Please note that there are still some uses of the phrase “other securities”
in the Registration Statement. Please delete this phrase throughout the Registration Statement.

Response:
The Fund has revised  this disclosure throughout the Registration Statement.

 9. Comment: Please advise how much the Fund expects to invest in hedge funds and private
equity funds that rely on Sections 3(c)(1) or 3(c)(7) of the 1940 Act (“Private Funds”). If the Fund expects to
invest more than 15% of the Fund’s assets in Private Funds, please note that registered investment funds that invest in such Private
Funds should impose a minimum investment amount of at least $25,000 and restrict sales of the Fund’s shares to investors that, at
a minimum, satisfy the accredited investor standard. Please explain why it would be appropriate to offer the Fund’s shares without
imposing these limits. The Staff may have additional comments after reviewing your response.

Response:
The Fund does not anticipate that it will invest more than 15% of its assets in Private Funds. Further, investment in Private Funds will
not be a principal investment strategy of the Fund.

 10. Comment: Please add a bullet stating under “Investing in our Common Shares involves
a high degree of risk…” that an investment in the Fund is suitable only for investors with the financial ability and willingness
to accept the high risks and lack of liquidity inherent in an investment in the Fund.

Response:
The Fund has added this disclosure on page i of the Registration Statement.

    Securities and Exchange Commission

    December 2,
    2022

    Page 4

 11. Comment: Where “return of capital” is discussed, please add additional language
to clarify that any capital returned to shareholders through distributions will be distributed after payment of fees and expenses.

Response:
The Fund has added disclosure on page 111 of the Registration Statement to clarify that should the Fund liquidate and return
capital to its shareholders, the Fund must first satisfy its obligations to its creditors, and shareholder distributions will be
made after payment of any applicable fees and expenses.

 12. Comment: In the last bullet under “Investing in our Common Shares involves a high
degree of risk…”, please revise the disclosure about the Fund’s ability to invest in “junk” securities
to specify the extent to which the Fund will invest in junk securities. We note disclosure on page 3, under the heading “What
types of investments do you intend to make” indicates the Fund will invest at least 80% of its total assets in “debt investments,”
most of which will consist of junk securities. Please consider adding additional clarifying language to the last bullet by noting that
the Fund “intends to invest significantly in ‘junk’ securities.”

Response:
The Fund has revised the disclosure on page i of the Registration Statement to add “We intend to invest
significantly in junk bonds.”

Prospectus Summary

 13. Comment: Please confirm if the instruments included in the graphic under “Who are
Ares and the Ares Credit Group” will be invested in as part of the principal investment strategies of the Fund, and, if so, confirm
that appropriate strategy and risk disclosure is included in the Registration Statement. The Staff believes that a reasonable shareholder
may believe that such instruments will be investments of the Fund, rather than those generally made by the Fund’s investment adviser.

Response: The
Fund has revised the disclosure  on page 1 of the Registration Statement to clarify that such graphic illustrates the spectrum of liquid and illiquid credit strategies currently managed by the Ares Credit Group. The Fund has further revised
the disclosure to clarify that although the Fund's objective is to bring the Ares Credit Group’s leading credit investment platform
to the Fund, the Fund may not principally in all of Ares Credit Group’s investment strategies and its investments across those strategies
may vary over time, perhaps materially.

 14. Comment:
                                            We note disclosure concerning Ivy Hill Asset Management, L.P. (“IHAM”). Please
                                            clarify the specific role IHAM has with respect to the Fund and how its role as a portfolio
                                            company of Ares Capital Corporation is relevant to the Fund. Please confirm if funds managed by IHAM are included in the calculation of the investment adviser's assets under management and why it
is appropriate and not misleading to shareholders to do so.

Response: The Fund confirms
that funds managed by Ivy Hill Asset Management, L.P. (“IHAM”) are included in the assets under management ("AUM") of Ares
Management Corporation (“Ares”) because IHAM is a related person of the Fund’s investment adviser, Ares Capital Management
LLC (“ACM”), and Ares Management LLC (“AM LLC”), as disclosed on their respective Forms ADV. ACM serves as the
investment manager to most of Ares' U.S. direct lending funds and institutional accounts, including the Fund and Ares Capital Corporation
(“ARCC”). ARCC directly or indirectly owns the equity and voting interests of its portfolio company, IHAM, which is registered
with the SEC as an investment adviser. AM LLC is the parent company of ACM and is registered with the SEC as an investment adviser. Both
ACM and AM LLC are subsidiaries of Ares. As a result, the Fund believes this presentation of the AUM of Ares is appropriate and consistent
with Ares’ SEC reporting.

    Securities and Exchange Commission

    December 2,
    2022

    Page 5

 15. Comment: In the first paragraph of “What types of investments do you intend to
make?”, the third sentence states that the “Fund may also invest in foreign instruments . . . .” If the Fund will not
invest principally in the securities of foreign issuers (including, if applicable, those located in emerging and/or frontier markets),
please relocate this disclosure to an appropriate section so that it will not be viewed as a principal investment strategy of the Fund.

Response:
The Fund has included such disclosure to page 62 of the Registration Statement under “Investment Objective and
Strategies” and has removed this disclosure from page 3 of the Registration Statement.

 16. Comment: The second paragraph of “What types of investments do you intend to make?”
states that the Fund “will generally not have direct rights against the underlying borrowers or entities that sponsor the CLOs.”
Please confirm that the attendant risks of not having these direct rights was added to the Risk Factors section concerning CLOs.

Response:
The Fund confirms that such disclosure is included on page 41 of  the Registration Statement under the Risk
Factor entitled “Our debt investments may be risky and we could lose all or part of our investment”.

 17. Comment: Please explain why the Fund proposes to delete “capital” from “capital
gains” when used in connection with the calculation of the Fund’s incentive fee (see Section 205(b)(3) of the Investment
Advisers Act of 1940, as amended, which uses the term “capital gains”).

Response:
The Fund has revised the disclosure throughout the Registration Statement to include “capital” in discussions of “capital
gains” when used in connection with the calculation of the Fund’s incentive fee.

 18. Comment: Please add disclosure to the Registration Statement to clarify if the Fund’s
pre-incentive fee investment income on which the Fund’s incentive fee is based excludes the shareholder servicing and/or distribution
fee, if any.

Response:
The Fund has revised the disclosure on page 19 of the Registration Statement to clarify that the
Fund’s pre-incentive fee net investment income on which the Fund’s incentive fee is based excludes any distribution
and/or shareholder servicing fees payable by the Class S Shares and the Class D Shares.

 19. Comment: Please confirm the Registration Statement includes disclosure regarding the
Fund being new and its performance, as well as any benefits it may derive from its affiliation with Ares Credit Group, have yet to be
realized.

Response:
The Fund confirms that such disclosure is included on page 22 of  the Registration Statement under the Risk
Factor entitled “We have a limited operating history”.

 20. Comment: Please confirm that the Registration Statement includes a graphical representation
and examples showing how the Fund calculates the incentive fee.

Response:
The Fund confirms that a graphical representation and examples showing how the Fund calculates the incentive fee are included
beginning on page 88 of the Registration Statement under “Incentive Fee".

 21. Comment: Your previous response in the August Response Letter indicated that the
Fund’s incentive fee is not based on a particular class and will be allocated to each class of shares based upon the relative proportion
of net assets represented by such class. Please add this language to the Registration Statement.

Response:
The Fund has added such disclosure  on pag