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                            November 28, 2023

       Justin Enbody
       Chief Financial Officer
       Kennedy-Wilson Holdings, Inc.
       151 S El Camino Drive
       Beverly Hills, California 90212

                                                        Re: Kennedy-Wilson
Holdings, Inc.
                                                            Form 10-K for the
year ended December 31, 2022
                                                            Filed February 22,
2023
                                                            File No. 001-33824

       Dear Justin Enbody:

              We have reviewed your October 6, 2023 response to our comment
letter and have the
       following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

               After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our September 12, 2023
       letter.

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

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Non-GAAP Measures and Certain Definitions, page 55

   1.                                                   We have considered your
response to our prior comment 1. Please address the following
                                                        with respect to your
response:
                                                            As your calculation
of same store revenue is calculated on a non-GAAP basis, please
                                                            revise your
disclosure to include a reconciliation of same property revenue to the
                                                            most directly
comparable measure calculated in accordance with GAAP. Reference
                                                            is made to Item
10(e) of Regulation S-K.
                                                            Based on your
response, it appears that same store NOI is not calculated on the same
                                                            basis as
consolidated NOI (e.g. elimination of above/below market rents, adjustments
                                                            for foreign
exchange rates). As such, please title the measure something other than
                                                            NOI and provide a
reconciliation to the most directly comparable measure calculated
 Justin Enbody
Kennedy-Wilson Holdings, Inc.
November 28, 2023
Page 2
           in accordance with GAAP. Reference is made to Item 10(e) of
Regulation S-K.
Item 8. Financial Statements and Supplementary Data
Note 2- Basis of Presentation and Summary of Significant Accounting Policies
Unconsolidated Investments, page 73

2.    We have considered your response to our prior comment 2. Please address
the following
      with respect to your response:
          Please tell us the consideration your performance allocation takes
(e.g. cash,
          ownership interests etc.)
          Tell us the type of services you perform in order to earn the
performance allocation
          (e.g. management services) and explain to us why you believe those
services are
          excluded from the scope of ASC Topic 606. In that regard, please
clarify for us the
          type of agreement that entitles you to a performance allocation (e.g.
management
          agreement, partnership agreement etc.) and the context in which the
performance
          allocation is discussed in that agreement.

       Please contact William Demarest at 202-551-3432 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters.



                                                          Sincerely,
FirstName LastNameJustin Enbody
                                                          Division of
Corporation Finance
Comapany NameKennedy-Wilson Holdings, Inc.
                                                          Office of Real Estate
& Construction
November 28, 2023 Page 2
cc:       In Ku Lee
FirstName LastName