March 3, 2020

Brandon E. Lacoff
Chairman of the Board and Chief Executive Officer
Belpointe REIT, Inc.
125 Greenwich Avenue, 3rd Floor
Greenwich, Connecticut 06830

       Re: Belpointe REIT, Inc.
           Post Qualification Amendment to Form 1-A
           Filed February 14, 2020
           File No. 024-10923

Dear Mr. Lacoff:

       We have reviewed your amendment 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 amending your offering statement and
providing the
requested information. 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 any amendment to your offering statement and the
information you
provide in response to these comments, we may have additional comments.

Post Qualification Amendment to Form 1-A

Offering Circular Cover Page, page i

1.    We note that you now intend to qualify as a REIT on such date as is
determined by your
      board of directors. Please disclose how the board will make such
determination and any
      factors that will be considered.
General

2.    We note that the risk factor on page 32 and the company's bylaws indicate
that the New
      York Supreme Court in New York, New York (or in some cases, other state
or federal
      courts in New York) is the exclusive forum for certain disputes between
the company and
      its stockholders. However, page 93 of the offering circular indicates
that the Circuit Court
      for Montgomery County, Maryland (or, if that court does not have
jurisdiction, the United
      States District Court for the District of Maryland, Southern Division) is
the exclusive
      forum. Please reconcile the disclosure.
 Brandon E. Lacoff
Belpointe REIT, Inc.
March 3, 2020
Page 2
3.     We note that the forum selection provision in your bylaws identifies the
New York
       Supreme Court in New York, New York, or, if that Court does not have
jurisdiction, the
       United States Southern District Court for the District of New York, as
the exclusive forum
       for certain litigation, including any "derivative action." Please
disclose whether this
       provision applies to actions arising under the Securities Act or
Exchange Act. In that
       regard, we note that Section 27 of the Exchange Act creates exclusive
federal jurisdiction
       over all suits brought to enforce any duty or liability created by the
Exchange Act or the
       rules and regulations thereunder, and Section 22 of the Securities Act
creates concurrent
       jurisdiction for federal and state courts over all suits brought to
enforce any duty or
       liability created by the Securities Act or the rules and regulations
thereunder. If the
       provision applies to Securities Act claims, please also revise your
prospectus to state that
       there is uncertainty as to whether a court would enforce such provision
and that investors
       cannot waive compliance with the federal securities laws and the rules
and regulations
       thereunder. If this provision does not apply to actions arising under
the Securities Act or
       Exchange Act, please also ensure that the exclusive forum provision in
the governing
       documents states this clearly, or tell us how you will inform investors
in future filings that
       the provision does not apply to any actions arising under the Securities
Act or Exchange
       Act.
        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        We remind you that the company 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 contact Ronald (Ron) Alper at 202-551-3329 or Pam Howell at
202-551-3357
with any questions.



                                                              Sincerely,
FirstName LastNameBrandon E. Lacoff
                                                              Division of
Corporation Finance
Comapany NameBelpointe REIT, Inc.
                                                              Office of Real
Estate & Construction
March 3, 2020 Page 2
cc:       Vanessa Schoenthaler
FirstName LastName