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                             September 12, 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 filing 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       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.                                                   Please address the
following with respect to your non-GAAP measures:
                                                            Please expand your
disclosure related to Co-Investment Portfolio NOI to clarify
                                                            whether the net
operating income presented represents the entirety of the operations
                                                            of the investees or
the company's share.
                                                            Please tell us, and
consider expanding your discussion of Co-Investment Portfolio
                                                            NOI to clarify, why
you make adjustments to net income for sale of real estate and
                                                            cost of real estate
sold when you also include adjustments for (gain)loss on sale of
                                                            real estate when
calculating net operating income.
                                                            It appears your
same property table on page 59 presents revenue on a non-GAAP
                                                            basis. Please tell
us how you have met all the disclosure requirements of Item
                                                            10(e)(i)(C) and
10(e)(i)(D) of Regulation S-K with respect to this measure.
 Justin Enbody
Kennedy-Wilson Holdings, Inc.
September 12, 2023
Page 2
             Please tell us whether your calculation of same store NOI on page
59 is consistent
           with your calculation of consolidated and co-investment NOI on page
57. In that
           regard, we note your disclosure on page 55 that same property
measures throughout
           your report are presented on a cash basis. Additionally, we note
that your calculation
           of same property NOI includes adjustments (such as adjustments for
straight-line rent
           and above/below market rents), and similar adjustments are not made
for
           consolidated or co-investment NOI.
Item 8. Financial Statements and Supplementary Data
Note 2 - Basis of Presentation and Summary of Significant Accounting Policies
Unconsolidated Investments, page 73

2.    Please explain to us how you determined your performance allocation
should be presented
      as a component of income from unconsolidated investments, and not
revenue. Cite any
      relevant accounting literature in your response.
        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.

        You may contact William Demarest at 202-551-3432 or Robert Telewicz at
202-551-
3438 if you have any questions.



                                                            Sincerely,
FirstName LastNameJustin Enbody
                                                            Division of
Corporation Finance
Comapany NameKennedy-Wilson Holdings, Inc.
                                                            Office of Real
Estate & Construction
September 12, 2023 Page 2
cc:       In Ku Lee
FirstName LastName