September 18, 2018

Vincent Tianquan Mo
Executive Chairman
Fang Holdings Limited
Block A, No. 20 Guogongzhuang Middle Street
Fengtai District, Beijing 100070
The People's Republic of China

       Re: Fang Holdings Limited
           Form 20-F for the Fiscal Year Ended December 31, 2017
           Filed May 15, 2018
           File No. 001-34862

Dear Mr. Mo:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

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

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

Form 20-F for the Fiscal Year Ended December 31, 2017

Operating and Financial Review and Prospects
Operating Results
Key Operating and Financial Performance Metrics, page 62

1.    Please tell us what consideration you gave to providing for the income
tax effects related
      to the adjustments to arrive at non-GAAP net income/(loss). Refer to
Question 102.11 of
      the C&DI for Non-GAAP Financial Measures. As part of your response, also
consider
      your computation of non-GAAP net income/(loss) and non-GAAP net
income/(loss)
      attributable to Fang Holdings Limited shareholders in your earnings
release on Form 6-K
      filed on August 28, 2018.
 Vincent Tianquan Mo
Fang Holdings Limited
September 18, 2018
Page 2

       In closing, 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 Melissa Walsh, Staff Accountant, at (202) 551-3224 or
Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 with any questions.



                                                          Sincerely,
FirstName LastNameVincent Tianquan Mo
                                                          Division of
Corporation Finance
Comapany NameFang Holdings Limited
                                                          Office of Information
Technologies
September 18, 2018 Page 2                                 and Services
FirstName LastName