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